Commission staff working document - Accompanying document to the Communication from the Commission to the European Parliament and the Council on enhancing the security of explosives - Impact Assessment {COM(2007) 651 final} {SEC(2007) 1423}
Date: 2007-11-06
Institutions: European Commission
Subjects: European Commission, cooperation policy, explosive, fight against crime, impact study, marketing, private sector, terrorism, traceability

COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 6.11.2007 
SEC(2007) 1421 

COMMISSION STAFF WORKING DOCUMENT 

Accompanying document to the 

COMMUNICATION FROM THE COMMISSION  TO THE EUROPEAN 
PARLIAMENT AND THE COUNCIL 

on enhancing the security of explosives 

IMPACT ASSESSMENT 

{COM(2007) 651 final} 
{SEC(2007) 1423} 

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TABLE OF CONTENTS 

Executive Summary ................................................................................................................... 5 

1. 

1.1. 

1.2. 

1.3. 

2. 

Procedural issues and consultation of interested parties .............................................. 7 

Organisation and timing............................................................................................... 7 

Consultation and expertise ........................................................................................... 7 

The Impact Assessment Board..................................................................................... 8 

Problem definition...................................................................................................... 10 

2.1.  What are the issues or problems that may require action?......................................... 10 

2.1.1.  General problem......................................................................................................... 10 

2.1.2.  Key concerns.............................................................................................................. 10 

2.1.2.1.  Public Security Aspects.............................................................................................. 10 

2.1.2.2.  The use of precursors ................................................................................................. 11 

2.1.2.3.  Supply Chain (storage, transport, traceability) .......................................................... 11 

2.1.2.4.  Detection .................................................................................................................... 11 

2.2. 

Analysis of specific problems, their causes and existing situation ............................ 12 

2.2.1.  Public Security Aspects.............................................................................................. 12 

2.2.1.1.  Specific problems....................................................................................................... 12 

2.2.1.2.  Scale of the problems and existing action.................................................................. 13 

2.2.2.  The use of precursors ................................................................................................. 14 

2.2.2.1.  Specific problems....................................................................................................... 14 

2.2.2.2.  Scale of the problems and existing action.................................................................. 14 

2.2.3.  Supply Chain (storage, transport, traceability) .......................................................... 17 

2.2.3.1.  Specific problems....................................................................................................... 17 

2.2.3.2.  Scale of the problems and existing action.................................................................. 17 

2.2.4.  Detection .................................................................................................................... 21 

2.2.4.1.  Specific problems....................................................................................................... 21 

2.2.4.2.  Scale of the problems and existing action.................................................................. 22 

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2.3.  Who is affected, in what ways, and to what extent? .................................................. 24 

2.4. 

2.5. 

How would the problem evolve, all things being equal? ........................................... 24 

Does the EU have the right to act?............................................................................. 25 

2.5.1.  General considerations ............................................................................................... 25 

2.5.2.  The added value of the European Union.................................................................... 26 

2.5.2.1.  The EU as a catalyst for cooperation ......................................................................... 26 

2.5.2.2.  The EU as a provider of funding for actions.............................................................. 27 

2.5.2.3.  EU legislation............................................................................................................. 27 

2.5.3.  Proportionality............................................................................................................ 28 

2.5.4.  Subsidiarity ................................................................................................................ 28 

3. 

4. 

4.1. 

4.2. 

4.3. 

4.4. 

5. 

5.1. 

5.2. 

Objectives................................................................................................................... 30 

Policy options............................................................................................................. 31 

Policy Option 1 – Status Quo..................................................................................... 32 

Policy Option 2 – Minimum Option .......................................................................... 33 

Policy Option 3 – Intermediate Option ...................................................................... 35 

Policy Option 4 – Maximum Option.......................................................................... 37 

Analysis of impacts .................................................................................................... 39 

Introduction ................................................................................................................ 39 

Policy option 1 – The status quo ................................................................................ 40 

5.2.1.  Assessment by action ................................................................................................. 40 

5.2.1.1.  Horizontal measures................................................................................................... 40 

5.2.1.2.  Prevention measures................................................................................................... 40 

5.2.1.3.  Detection measures .................................................................................................... 40 

5.2.2.  Overall assessment of Policy Option 1 ...................................................................... 40 

5.3. 

Policy option 2 – Minimum option ............................................................................ 40 

5.3.1.  Assessment by action ................................................................................................. 40 

5.3.1.1.  Horizontal measures................................................................................................... 41 

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5.3.1.2.  Prevention measures................................................................................................... 42 

5.3.1.3.  Detection Measures.................................................................................................... 43 

5.3.1.4.  Preparedness and response measures ......................................................................... 45 

5.3.2.  Overall assessment of Policy Option 2 ...................................................................... 45 

5.4. 

Policy option 3 – Intermediate option........................................................................ 46 

5.4.1.  Assessment by action ................................................................................................. 46 

5.4.1.1.  Horizontal measures................................................................................................... 46 

5.4.1.2.  Prevention Measures .................................................................................................. 47 

5.4.1.3.  Detection Measures.................................................................................................... 49 

5.4.1.4.  Preparedness and response measures ......................................................................... 50 

5.4.2.  Overall assessment of Policy Option 3 ...................................................................... 51 

5.5. 

Policy option 4 – Maximum option ........................................................................... 51 

5.5.1.  Assessment by action ................................................................................................. 51 

5.5.1.1.  Prevention Measures .................................................................................................. 51 

5.5.1.2.  Detection measures .................................................................................................... 54 

5.5.2.  Overall assessment of Policy Option 4 ...................................................................... 55 

5.6. 

Overall assessment ..................................................................................................... 56 

6. 

6.1. 

6.2. 

7. 

The preferred Policy option ....................................................................................... 57 

Challenges in identifying the preferred option........................................................... 57 

The preferred option................................................................................................... 58 

Monitoring and evaluation ......................................................................................... 64 

ANNEX 1 – DETAILED ASSESSMENT OF POLICY OPTIONS ....................................... 67 

ANNEX 2 – LIST OF ESETF RECOMMENDATIONS........................................................ 67 

ANNEX 3 – SUMMARY ASSESSMENT TABLE.............................................................. 120 

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EXECUTIVE SUMMARY 

Explosive devices remain the most used vector in terrorist attacks. They were responsible for 
the  vast  majority  of  the  victims  of  terrorist  attacks  over  the  last  50  years.  Consequently, 
enhancing  the  security  of  explosives  and  making  the  production  of  explosive  devices  for 
terrorists more difficult has been and continues to be a priority for the European Union. 

On 25 March 2004, in the immediate aftermath of the Madrid attacks, the European Council, 
in  its  Declaration  on  Combating  Terrorism,  established  as  a  priority  the  need  "to  ensure 
terrorist  organisations  and  groups  are  starved  of  the  components  of  their  trade".  The 
European Council noted in particular on this occasion that “there is a need to ensure greater 
security of firearms, explosives, bomb-making equipment and technologies". 

In  response,  the  Commission  began  to  develop  a  policy  on  enhancing  the  security  of 
explosives.  

One of the key measures undertaken by the Commission was the setting up of an Explosives 
Security Experts Task Force (ESETF), composed of private and public sector representatives, 
with  a  view  to  preparing  recommendations  for  actions  in  the  explosives  security  field.  The 
ESETF  completed  its  work  in  June  2007  with  the  identification  of  50  recommendations  for 
actions. 

The general objective of an EU Action Plan on Enhancing the Security of Explosives would 
be  to  reduce  the  number  and  potency  of  terrorist  incidents  in  the  EU  using  explosives.  The 
underlying  goal  would  therefore  be  to  protect  society  from  the  threat  of  attacks  using 
explosive devices while taking into full consideration the multiple areas of economic activity 
in which explosives and their precursors are used for the benefit of all. 

The EU Action Plan would be based on the recommendations made by the ESETF and would 
be organized under four headings: 

•  Horizontal  Measures  –  aimed  at  improving  exchanges  of  information,  the 

development of threat assessments and research.  

•  Prevention  Measures  –  focusing  on  awareness  raising,  control  and  regulation  of 
precursors, increased control on the market of explosives and pyrotechnic articles, 
vetting  and  security  measures  in  explosives  facilities  and  transport  and  internet-
related actions.  

•  Detection  Measures  –  proposing  scenarios,  minimum  standards,  exchanges  of 
information and EU-wide certification, testing and trialling schemes for detection 
tools.  

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•  Preparedness  and  Response  Measures  –  including  the  establishment  of  an  EOD 
network  and  liaison  with  mobile  telephone  providers  on  the  shutting  down  of 
antennas. 

Four policy options have been identified concerning the establishment of an EU Action Plan 
on  Enhancing  the  Security  of  Explosives.  These  options  have  been  elaborated  based  on  the 
recommendations for specific actions set fourth in the ESETF report and group together the 
various ESETF recommendations depending on their impact: 

•  Policy Option 1 – Status Quo 

•  Policy Option 2 – Minimum Option 

•  Policy Option 3 – Intermediate Option 

•  Policy Option 4 – Maximum Option 

A  detailed  assessment  of  the  four  policy  options  lead  to  conclusion  that  in  general  terms, 
Policy  Option  4  is  the  preferred  option  with  the  stipulation  however  that  further  feasibility 
studies and consultations need to be taken forward concerning some of the actions identified 
in Option 4. 

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1. 

PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 

1.1. 

Organisation and timing 

Reference number: 2007/JLS/008 

Following the Madrid terrorist attacks of March 2004, the Commission started intensive work 
on the issue of the security of explosives. Since several services have an interest in the field of 
the security of explosives, an explosives inter-service group was setup. The group was chaired 
by DG JLS and included the following services: DG TREN, DG ENTR, DG ENV, JRC and 
SG. 

The inter-service group played a pivotal role in developing the explosives action plan.  

The Commission Legislative and Work Programme 2007 states that in the preparation of the 
Explosives  Security  Action  Plan,  the  Commission's  objective  is  to  stimulate  debate  and 
dialogue  with  all  actors  involved  in  the  security  of  explosives.  This  expertise  will  be  taken 
into account in the preparation of an EU Action Plan for the enhancement of the security of 
explosives and firearms. 

A  significant  amount  of  data-gathering  needed  for  the  preparation  of  this  report  was 
undertaken  through  an  external  study.  The  external  study  constitutes  an  important  basis  for 
this  report.  The  problems,  objectives  and  the  assessment  of  the  various  policy  options  were 
based to a large extent on the final report from the contractor prepared in close consultation 
with  the  Commission  and  on  the  basis  of  a  desk  analysis  of  appropriate  methods  and 
applicable legal documents. The external study and this report have been drafted on the basis 
of numerous contacts between the Directorate-General for Justice, Freedom and Security and 
the contractor as well as meetings of an inter-service steering group. The report will be made 
public  on  the  DG  JLS  website  subject  to  scrutiny  of  certain  parts  for  reasons  of 
confidentiality. 

roadmap 

A 
initiative  was  produced  and 
http://ec.europa.eu/atwork/programmes/docs/clwp2007_roadmap_priority_initiatives.pdf 

is  publicly  available  at 

this 

for 

1.2. 

Consultation and expertise 

All relevant stakeholders have participated and been consulted concerning the development of 
the Explosives Action Plan. This has been done through the following measures: 

•  In  July  2005,  the  Commission  adopted  a  Communication  on  the  Security  of 
Explosives which launched a broader debate in the field. The Communication put 
forward several ideas for action which were undertaken in subsequent years. This 
included the creation of the Explosives Security Experts Task Force (ESETF). 

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•  The 1st EU Conference on the Security of Explosives has held in October 2006 in 
Brussels.  The  event  started  the  implementation  of  the  public-private  dialogue  as 
announced  in  the  Commission  Communication  on  enhancing  the  security  of 
explosives of July 2005. 

•  The  Explosives  Security  Experts  Tasks  Force  was  set  up  in  2007  to  assist  the 
Commission in the preparation of the Action Plan. The ESETF was composed of 
public and private sector representatives – over 100 in total. The Task Force was 
divided  into  four  Working  Groups,  looking  at  Precursors,  Supply  Chain, 
Detection and Public Security Aspects. The first version of the Task Force report, 
comprising the recommendations prepared by all Working Groups, was submitted 
to the Commission beginning of May 2007. Following consultation with the Task 
Force members, a second version was submitted one month later. The work of the 
Task  Force  culminated  in  June  2007  with  the  submission  of a  report  identifying 
50 recommendations for actions designed to strengthen the security of explosives 
in the EU. This Impact Assessment report analyses all of the measures identified 
by  way  of  the  Task  Force  recommendations  reorganized  under  three  strategic 
pillars:  prevention,  detection  and  response;  and  one  overarching  set  of  measures 
having a horizontal  application.  With  a view to making the draft Action Plan as 
clear as possible, some of the original 50 ESETF recommendations were merged 
into single actions. 

•  A 2nd EU Conference on the Security of Explosives was held in Braga (Portugal) 
on 16-17 July 2007 with the participation of around 150 private and public sector 
representatives.  The  event  was  organized  jointly  by  the  Commission  and  the 
Portuguese EU Presidency. The aim of the conference was to discuss the ESETF 
recommendations  and  the  draft  EU  Action  Plan.  The  conference  demonstrated 
strong support for the Commission's activities in the explosives security field.  

1.3. 

The Impact Assessment Board 

On 3 September 2007, the Impact Assessment Board of the European Commission delivered 
an opinion regarding a preliminary version of this Impact Assessment report. In the opinion, 
the Board in brief stated that the IA report would gain robustness and clarity if the assessment 
would be focused on the measures with most significant impacts, if the EU value added and 
right to act are explained for each measure separately, and if the choice of which options to 
carry forward and which options to hold back for further study is better explained. The Impact 
Assessment Board further gave the following comments: 

(1) The conclusion on which measures to carry forward and which to refer back for further 
assessment should be made more transparent.  

(2) The EU right to act and value added should be demonstrated for every measure.  

(3) Measures with significant impacts should be assessed in more detail than measures with 
minor impacts. 

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The present version of the Impact Assessment report has been significantly redrafted, with a 
view  to  taking  these  recommendations  fully  into  account.  Additional  information  and 
modifications to take account of some more detailed comments have also been introduced. 

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2. 

PROBLEM DEFINITION  

2.1.  What are the issues or problems that may require action? 

2.1.1.  General problem 

The  main  problem  which  needs  to  be  addressed  is  the  use  of  explosives  and  explosives 
precursors to commit terrorist acts. Explosive devices remain the most used vector in terrorist 
attacks. They were responsible for the vast majority of victims of terrorist attacks over the last 
50 years.  

2.1.2.  Key concerns 

The general problem identified above can further be described by identifying top level issues 
of concern in four areas:  

(1) 

public security 

(2) 

precursors 

(3) 

supply chain  

(4) 

detection.  

These  four  fields  correspond  to  the  specific  areas  of  work  within  the  ESETF.  The  main 
problems identified in these areas are set out below. The specific problems falling under these 
four areas are identified and analyzed in the next section. 

2.1.2.1.  Public Security Aspects 

This area addresses issues relevant to the overall security of the EU and its citizens. It can be, 
in  a  sense,  considered  to  have  a  horizontal  ‘umbrella’  function  for  the  three  more  specific 
sectors discussed above. 

The two overall problems identified are: 

(1) 

(2) 

Some Member States have better measures in place to enhance the security of 
explosives  than  others.  Due  the  absence  or  reduction  of  borders  in  the  EU, 
terrorists  and  criminals  may  engage  in  ‘explosives  shopping’  or  transport 
explosives  from  third  countries  where  border  control  and  detection  is  at  a 
relatively lower level. 

Information  sharing  and  cooperation  between  Member  States  exists  in 
multilateral and bilateral forms, but seems to be scattered and not covering all 
countries of the EU. This may lead to important information gaps and a lack 
of early warning opportunities. 

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2.1.2.2.  The use of precursors 

The  area  of  precursors  is  highly  complex,  as  it  not  only  comprises  a  high  number  of 
substances but also issues in relation to their storage, transport and illicit use to manufacture 
improvised explosive devices (IEDs). The two overall problems identified are: 

(3) 

(4) 

Explosives  manufactured  from  precursors  have  been  used  in  at  least  eight 
major  terrorist  attacks  in  the  past  15  years  (including  Bali,  Oklahoma  and 
London), killing over 500 persons. 

There  are  masses  of  materials  and  substances  available  that  can  be  used  to 
make  explosives.  There  are  legitimate  reasons  for  having  these  in  our 
societies  and  insufficient  knowledge  on  the  availability  of  materials  or 
substances to substitute these or to make them safer. Some of the alternatives 
may be very expensive. 

2.1.2.3.  Supply Chain (storage, transport, traceability) 

Supply Chain covers the production of explosives from the beginning to their end use. It thus 
includes  the  manufacturing  process,  storage  in  the  production  plant,  transactions,  transport, 
storage  at  the  ‘customer’s’  end  and  the  end  use  of  explosives.  The  process  also  includes 
aspects of accounting, record-keeping, licensing and staff vetting. The two overall problems 
identified are: 

(5) 

Legally  produced  explosives  have  been  misappropriated  from  production, 
storage,  distribution  and  end  user  sites  or  purchased  unauthorised.  Several 
major thefts of explosives have occurred during the last 10 years. 

(6)  Manufactured  explosives  are  stored  in  and  moved  to  many  different  places, 
with  many  different  users  and  providers.  Legislation  in  this  area  (i.e.  the 
Explosives  Directive)  is  aimed  at  harmonising  safety  standards.  Security 
legislation and measures at national level however vary a great deal. 

2.1.2.4.  Detection 

When the prevention activities described above have failed or have been circumvented, it is 
up  to  detection  tools  and  practices  to  limit  the  risk  of  terrorist  attempts  to  use  explosives. 
Detection technologies and devices have however substantial limits and will not, at least on 
the short-medium term, be able to detect all explosives and substances that can be turned into 
explosives. The five overall problems identified are: 

(7) 

The  present  likelihood  that  terrorists  illicitly  handling  and  using  explosives 
and precursors are detected may not be sufficient in all locations and even in 
locations where detection equipment is already deployed. 

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(8) 

(9) 

Purchasers of detection technologies and devices are insufficiently aware and 
sometimes  ‘misinformed’  about  the  performance  of  the  equipment  and 
systems and about the best way to deploy and operate these in an efficient and 
effective  way.  Producers  of  such  equipment  and  systems  are  experiencing 
difficulties to develop systems that match the needs of their clients. 

There  is  a  lack  of  single  market  integration  with  regard  to  detection 
technologies. This makes them more costly and not as efficient as they could 
be. 

(10)  There are duplications and overlaps in Member States’ activities to determine 
the quality of detection equipment. In  addition,  there is limited  exchange of 
information among relevant public authorities across the EU on these matters. 

(11)  Difficulties  exist  with  regard  to  the  rolling  out  of  new  solutions  and 
technologies  stemming  from  research  onto  the  market.  There  is  an  overall 
lack of mechanisms which could bring the research results closer to the end 
user, considering cost-benefits of the solution, operational requirements, etc. 

2.2. 

Analysis of specific problems, their causes and existing situation 

2.2.1.  Public Security Aspects 

2.2.1.1.  Specific problems 

The following specific problems can be identified: 

•  There is a lack of an overall EU system coordinating and providing information to 

relevant national authorities on explosives and explosive incidents. 

•  There is a lack of networking and coordination in the area of explosives including 

all Member States. 

•  Existing information sharing and cooperation activities do not always involve and 

inform all relevant national departments. 

•  The  EU  does  not  have  an  Early  Warning  System  in  place  to  inform  Member 
States  of  imminent  threats,  thefts,  suspicious  transactions  and  other  terrorist 
activity 

•  There is a lot of information freely available on the Internet on bomb-making 

•  There is an overall lack of research in the area of explosives, explosive precursors 

and detection. 

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2.2.1.2.  Scale of the problems and existing action 

International and EU level 

Since the early nineties, thousands of people across the world have died because of both small 
and large-scale terrorist bombings. Many more persons were injured. In the EU in that same 
period,  the  use  of  explosives  for  terrorist  purposes  accounted  for  at  least  300  deaths  and 
around 2,000 people injured. The TE-SAT1 report estimates that in 2006 alone, a total of 498 
terrorist attacks (overall, not necessarily using explosives) were carried out in the EU. Whilst 
the  majority  resulted  in  limited  material  damage  and  were  not  intended  to  kill,  the  failed 
attack  in  Cologne  (DE)  and  the  foiled  London  plot  demonstrates  that  terrorists  still  aim  at 
mass casualties. The report further concludes that a large number of various types of terrorist 
organisations  have  an  active  presence  in  the  EU,  some  of  them  directly  targeting  Member 
States or Third States interests’ in Member States. 

One of the factors making it relatively ‘easier’ for terrorists to strike or prepare attacks is the 
fact  that  despite  the  common  EU  legislation  and  action  to  combat  terrorism,  in  practical 
security terms some Member States have better measures in place to enhance the security of 
explosives  than  others.  This  has  for  example  led  to  several  cases  of  ‘explosives  shopping’, 
such  as  ETA  avoiding  the  very  severe  and  tight  Spanish  regulatory  and  institutional 
framework by obtaining explosives from another EU country in the Schengen area. However, 
even  the  Spanish  system  was  not  watertight  as  the  explosives  used  on  the  11  March  2004 
bombings originated from a mine in northern Spain. The use of explosives originating outside 
the EU for terrorist bombings in one of the Member States also shows that despite all external 
border controls it is still difficult to detect the illegal import of explosives. 

There  are  several  mechanisms  in  place  that  focus  on  practical  cooperation  and  information 
sharing. The most recent and relevant one is the Explosives Security Experts Tasks Force, 
set  up  in  2007  as  a  result  of  the  July  2005  Communication  on  “Measures  to  ensure  greater 
security  in  explosives,  detonators,  bomb-making  equipment  and  firearms”.  The  Task  Force 
assisted  in  the  preparation  of  the  EU  Action  Plan  for  the  enhancement  of  the  security  of 
explosives,  subject  of  this  impact  assessment.  The  multi-stakeholder  Task  Force  including 
both the public and private sectors concentrated, through four separate working groups, on the 
issues of precursors, supply chain, detection and public security.  

National level 

Domestic  agencies  responsible  for  general  security,  safety  and  internal  issues  vary  greatly 
between the Member States. Agencies broadly include a combination of Ministries for supply 
chain  matters  (e.g.  Ministries  of  Interior,  Justice,  Industry  /  Enterprise  and  Transport),  the 
Ministries  of  Defence,  Interior,  Justice  and  Economy  for  safety  issues  and  the  Ministries  of 
Foreign Affairs, Justice and Interior for international issues. The police, often in the form of 
specialised bomb squads / centres, are in most Member States involved in detection, general 

1 

EU terrorism situation and trend report 2007, Europol, April 2007. 

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security  and  safety  matters.  A  number  of  countries  have  established  inter-agency  working 
groups and / or committees to cooperate and exchange information. Some have joint access to 
database  and  other  information  tools,  while  others  organise  regular  meetings  to  coordinate 
actions. 

2.2.2.  The use of precursors 

2.2.2.1.  Specific problems 

The following specific problems can be identified: 

•  Insufficient awareness of staff handling precursors (in the widest sense) in terms 

of detecting illicit activities and suspicious actions 

•  Insufficient  knowledge  on  how  to  modify  or  restrict  the  nature  of  precursors  to 

make their use in manufacturing explosives more difficult. 

•  Lack of systems to monitor and report on suspicious transactions in B2B (business 
to business or upstream transactions) and B2C (business to consumer) relations. 

•  Existing legislation and voluntary actions concerning the storage and transport of 

precursors does not sufficiently address security issues. 

2.2.2.2.  Scale of the problems and existing action 

A worrying share of terrorist bombings since the beginning of the nineties included the use of 
precursors  turned  into  explosives.  A  non-exhaustive  list  of  large-scale  terrorist  bombings 
across the globe shows that this use has been stable, if not increasing, over the last 15 years. 
Together, these eight major incidents listed in the table below caused nearly 500 deaths and 
more than 3,000 injured. 

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Table 2.2 – Overview of terrorist bombings using precursors 

Year 

Location 

Death 

Injured 

1992 

St Mary’s Axe / 
Docklands, London, UK 

1993 

WTC, New York, USA 

1993 

Bishops Gate, London, 
UK 

3 

6 

1 

1995 

Oklahoma City, USA 

168 

1996 

Canary Wharf / 
Docklands, UK 

1996 

Manchester, UK 

0 

0 

1998 

Omagh, Northern Ireland  29 

2002 

Bali nightclubs, 
Indonesia 

202 

2005 

London subway. UK 

56 

0 

1000 

40 

1000 

39 

200 

200 

209 

700 

It  is  also  important  to  consider  the  number  of  attacks  that  were  unsuccessful  (e.g.  London 
both in July 2005 and June 2007) involving Improvised Explosive Devices (IEDs), as well as 
the high amount of seizures of substances, especially ammonium nitrate fertilizer destined to 
that end. Little evidence is available but this may well amount to many tons over the past 30 
years. 

Precursors to explosives 

There  are  hundreds  of  precursors  with  explosive  potential  and  thousands  that  can  have  an 
explosive reaction when put together. Many of these are legal to purchase and widely used in 
everyday  life.  Many  Member  States  have  the  ability  to  identify  explosive  precursors  before 
and  after  detonation,  but  this  is  often  very  difficult  due  to  the  small  samples  available  post 
blast and the fact that some precursors cannot be identified when working with samples only. 

By the nature of their choice of tactic, many terrorists are most likely interested in chemicals 
that  are  high  impact  (able  to  cause  substantial  damage  and  serious  injury  to  a  significant 
number of people) and feasible to use  (easy to deploy / manufacture, difficult to detect and 
readily accessible). However, especially suicide bombers are known to have used IEDs with a 
smaller destruction potential, containing only small amounts of dangerous chemicals, which 

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are even more difficult to detect. Such explosive devices can be produced without using any 
specific equipment, following bomb recipes on the Internet, and their components are easy to 
obtain.  Contrary  to  drugs  precursors  for  which  the  demand  and  production  is  constant,  the 
demand  of  terrorists  is  usually  ‘one-off',  as  attacks  only  require  the  ‘right’  (i.e.  a  relatively 
small) quantity of chemicals to be used in a single attack. This makes it even more difficult to 
identify transactions or any other activity aimed at manufacturing explosives from precursors. 

There  are  additives  that  can  reduce  the  explosive  properties  of  some  of  the  most  dangerous 
chemicals. Other chemicals could, to some extent, be replaced by less explosive alternatives. 
There  is  insufficient  knowledge  and  research  in  this  area  to  come  forward  with  solutions 
which are effective and cost-efficient.  

Overall, the chemical industry is rather sceptical about the possible application of inhibitors 
and  additives,  especially  for  the  upstream  market  (other  industrial  producers  using  the 
chemicals). As the effect of inhibitors is basically a neutralising one – especially in the case of 
acids – this would have a strong adverse impact on the utility of the chemical in question as a 
commodity/intermediate product.  

With the high number of chemicals that are being produced and sold throughout the EU, staff 
working in the industry is not sufficiently aware of which precursors are most dangerous and 
which transactions should be considered suspicious. Without this knowledge, there is a danger 
that  such  transactions,  or  also,  for  example  thefts,  are  not  reported  to  the  appropriate 
authorities.  

Only  a limited  number of Member States have put in place systems or activities to monitor 
B2B  and  B2C  transactions  in  precursors  which  may  be  suspicious.  These  include  policy 
advice,  cooperation  with  end  users,  the  publication  of  guidelines  and  the  establishment  of  a 
monitoring  system.  The  UK,  for  example,  recently  launched  the  ‘Know  your  Customer’ 
campaign  which  encourages  retailers  to  consider,  on  the  basis  of  a  series  of  targeted 
questions, whether a certain transaction should be reported to the authorities. The campaign 
refers  to  a  number  of  very  specific  chemicals.  Similarly,  the  chemical  industry  in  the  UK 
(“upstream”:  producers  of  components  and  intermediate  products)  also  have  a  Code  of 
Conduct  in  place  linked  to  the  identification  and  reporting  of  suspicious  transactions. 
Substances used predominantly for chemical weapons or drugs (such as acetones), are on the 
industry’s monitoring list. 

Relevant EU legislation in the area mainly focuses on safety rather than on the security of the 
products  and  installations.  Instruments  such  as  the  Fertilizers  Regulation  (EC)  No 
2003/2003, the Reach Regulation (No 1907/2006) and the Seveso II Directive (96/82/EC) 
all include extensive safety requirements, as well as provisions to improve the protection of 
human health and the environment, whilst insufficient attention is paid to security issues. 

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2.2.3. 

Supply Chain (storage, transport, traceability) 

2.2.3.1.  Specific problems 

The following specific problems can be identified: 

•  There are great differences in the extent to which Member States have regulated 
and  are  enforcing  security  measures  concerning  the  storage  and  sales  of 
commercial  explosives.  This  includes  raw  materials  used  in  the  manufacture  of 
explosives. 

•  Despite  the  Directive  on  the  harmonisation  of  the  provisions  relating  to  the 
placing  on  the  market  and  supervision  of  explosives  for  civil  use  and  ADR 
legislative  instruments,  surveillance,  protection  and  tracking  systems  for  the 
transport of explosives may not go far enough for security purposes. 

•  Whilst nearly all Member States have measures in place to vet personnel working 
with  explosives,  the  level  and  coverage  of  the  screening  varies  greatly  (from 
merely  checking  vocational  competences  and  criminal  records  to  psychological 
tests and in-depth background checks). 

•  The  labelling  of  explosives  is  not  undertaken  by  all  Member  States  and  is  not 
carried  out  in  a  harmonised  way,  except  in  specific  relation  to  intra-community 
transfers. 

•  Not all Member States have systems in place to alert producers, distributors and 

transport companies of regional threats. 

2.2.3.2.  Scale of the problems and existing action 

A  high  share  of  terrorist  bombings  since  the  beginning  of  the  nineties  included  the  use  of 
commercial  explosives  (as  opposed  to  IEDs).  The  origin  of  most  of  these  explosives  is 
unclear in most cases (i.e. it is not public whether these were explosives legally produced in 
the  relevant  geographical  zone  or  whether  they  were  smuggled  illegally  into  the  territory). 
The  following,  non-exhaustive  list  of  large-scale  terrorist  bombings  across  the  globe  shows 
that the use of such explosives has been stable over the past 15 years, together causing around 
1300 deaths and nearly 5,000 injured. 

Table 2.5 – Overview of terrorist bombings using commercial explosives 

Year 

Location 

1993 

Bombay car and scooter 
bombs, India 

Death 

317 

Injured 

1200 

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1996 

Khobar Towers, Saudi 
Arabia 

1998 

Kenya & Tanzania 

1999 

Moscow flats, Russia 

2000 

USS Cole, Yemen 

2002 

Limburg oil tanker 

2003 

Istanbul, Turkey 

2003 

Casablanca suicide 
bombings, Morocco 

19 

224 

272 

17 

1 

28 

41 

2004 

Madrid railway, Spain 

191 

2006 

Mumbai railroad, India 

190 

372 

1000 

400 

39 

12 

450 

100 

600 

625 

Major  incidents  or  alarm  to  the  general  public  concerning  legal  explosives  manufactured, 
transported  and  stored  in  the  EU  are  rare.  The  safety  record  of  the  explosives  industry  is 
considerably better than most other industries of a similar nature. However, there have been 
several major thefts of explosives, including the huge amounts of Semtex seized from the ship 
Claudia in the seventies and several ETA thefts of commercial explosives from quarries and 
other locations in France.  

Explosives industry 

The  Federation  of  European  Explosive  Manufacturers  (FEEM)  estimates  that  close  to  one 
million tonnes of explosives are detonated every year in Europe for civil purposes. The main 
clients are: 

•  The mining industry; 

•  The quarrying industry; 

•  Construction  and  civil  engineering,  mainly  for  demolition,  land  clearance  and 

tunnelling; 

•  Other industrial uses, such as metal fabrication and activities where rapid force is 

required (such as air bags). 

In  terms  of  scale,  the  mining  and  quarrying  industries  consume  the  majority  of  explosives. 
The  market  for  civil  explosives  in  Europe  is relatively  small  by  international  standards  (see 
Figure 2.6 below). In 2001 North America consumed around 2.5 million tonnes of explosives 

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(39% of the global total), and Asia a further 1.3 million tonnes (21% of the global total). The 
mining  and  quarrying  industries  in  the  EU27  countries  accounted  for  just  8%  of  global 
consumption (0.5 million tonnes).  

On  the  basis  of  the  information  available,  the  production  of  explosives  seems  to  be  a 
relatively stable industrial sector in the EU in the last three years. Ten years ago, the volume 
produced  was  substantially  lower  than  in  2005,  whilst  the  total  value  was  relatively  higher. 
According  to  the  impact  assessment  on  the  Traceability  Directive2,  the  European  industrial 
explosives business environment is highly competitive. Overcapacity exists and consumption 
is  not  growing.  Manufacturers  have  been  and  will  continue  to  be  forced  to  rationalize  and 
concentrate  their  businesses.  Further  efforts  to  expand  business  across  national  boundaries, 
especially by larger participants purchasing smaller ones, can be expected. 

Transport and storage 

With the exception of explosives that are mixed onsite, a great deal of explosives are moved 
for national and Intra-community trade and for export outside the EU. Whilst it is impossible 
to  find  data  on  internal  movements,  in  2006  nearly  30,000  tonnes  of  explosives  were 
transported from one Member State to another and nearly 14,000 tonnes were transported to 
third countries.  

Whilst all Member States have to some extent regulated and made practical arrangements for 
the storage and transport of explosives, these vary greatly between each other despite EU and 
national regulatory requirements.  

Overall,  very  few  of  the  measures  in  place  in  the  EU  Member  States  are  based  on  in-depth 
risk  assessments  of  the  actual  storage  /  production  plant.  With  regard  to  storage,  measures 
range  from  special  requirements  on  construction,  alarms,  record-keeping  and  fencing  to 
monitoring by guards or surveillance systems and police control. In addition, whilst security 
requirements  may  be  very  strict  and  regularly  monitored  in  sites  where  explosives  are 
manufactured, stored and distributed, there seems to be less control on end user sites, such as 
quarries  and  construction  sites.  For  example,  the  explosives  used  in  the  Madrid  bombings 
were stolen explosives from a quarry in the northern town of Tineo (Spain) with the help of a 
Spanish quarryman. 

With  regard  to  transport,  measures  include  police  escorts,  inspections,  GPS  surveillance, 
notification to the police, licensing of movements, the use of armed forces (in case of military 
transports),  alerts  to  border  guards  in  case  of  cross-border  movements,  the  use  of  armed 
private  security  guards,  permanent  radio  contact  and  the  use  of  blocking  systems.  Based  on 
the numbers of EX/II and EX/III vehicles3 in Sweden (40) and the Czech Republic (50), it is 
estimated that the total number of vehicles transporting civil explosives is around 450 in the 

2 

3 

Impact  Assessment  Report  –  proposal  for  a  Commission  Directive  setting  up,  pursuant  to  Council 
Directive 93/15/EEC, a system for the identification and traceability of explosives for civil uses. 
EX/II- and EX/III refers vehicles used specifically for the transport of dangerous goods. 

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EU. Mobile Explosive Manufacturing Units, used for onsite production of explosives, are less 
prone to thefts. Based on their numbers in the Czech Republic (5) and Sweden (10), their total 
number is estimated to be relatively low, around 100 in total in the EU. 

The  arrangements  described  above  have  two  things  in  common:  a)  their  focus  is  often  on 
safety and less on security; and b) difficulties are encountered in the case of small quantities 
(e.g. up to 10 kilo). The differences between national arrangements have, in a few cases, had a 
‘displacement’  effect.  For  example,  Spain  has  one  of  the  strictest  systems  to  ensure  the 
security  of  explosives,  due  to  the  presence  of  E.T.A  on  its  territory.  However,  in  a  Europe 
without  borders,  it  has  been  relatively  'easy'  for  this  terrorist  organisation  to  steal  and  /  or 
illegally purchase explosives in other Member States with a less tight regulatory framework 
and  systems  of  control.  Finally,  whilst  some  countries  have  some  form  of  alert  system  in 
place  in  case  of  thefts  or  to  retrace  lost  or  stolen  explosives,  these  systems  often  do  not 
comprise early warnings in case of threats in particular regions or areas. 

Persons handling explosives 

Personnel handling or having access to explosives have to undergo a background check in all 
Member  States.  However,  the  level  of  screening  seems  to  vary.  Some  countries  only  check 
whether the person has the appropriate professional competences to safely handle explosives. 
Others include a check of criminal records and more far-reaching background checks (mental 
and  physical  health,  use  of  substances,  etc).  Cyprus,  for  example,  mentions  the  checking  of 
the person’s character, which may refer to the use of psychological testing. 

Traceability 

With regard to the labelling of explosives, it appears that nine countries mark explosives for 
licensing and record-keeping requirements. Three Member States are operating  databases to 
improve tracking, tracing and record-keeping systems of all explosives. Several countries are 
considering developing such databases. When asked about marking explosives, many refer to 
the CE sign for safety standards, as well as to other forms of marking through barcodes, batch 
numbers,  etc.  However,  existing  conventions  and  regulations  covering  the  transport  of 
dangerous  goods  such  as  explosives,  allow  packages  containing  these  goods,  but  not  the 
goods themselves, to be traced rapidly. If the original packaging is changed, it is unlikely that 
the contents can be identified. 

In line with the Montreal Convention, all Member States are obliged to use chemical agents to 
market plastic explosives. Other types of commercial high explosives are not tagged. At the 
same  time,  tagging  or  marking  of  the  actual  explosives  has  its  limits,  as  traces  of  such 
taggants remain permanently in the material that exploded. For example, limestone which is 
first blasted and then turned into concrete will include the taggant of the first explosive used. 
If this concrete, at a later stage, is blasted again with another marked explosive, it seems that 
it is no longer possible to identify which explosives were used when. This would imply that in 
time,  traces  of  different  taggants  can  be  found  practically  everywhere.  Some  industrial 
stakeholders also claim that it is highly expensive. 

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The  vast  majority  of  Member  States  have  the  ability  to  identify  certain  explosives  and 
explosive  materials  found  before  and  after  detonation.  Problems  highlighted  include  the 
difficulties  of  identifying  the  type  of  detonator  or  explosive  used  due  to  the  CE  instead  of 
national marking and the small samples available post blast. 

Legislation 

When looking at legislation in place, the most relevant instruments are the Council Directive 
93/15/EEC on the harmonisation of the provisions relating to the placing on the market 
and supervision of explosives for civil uses, which imposes a uniform set of manufacturing 
and quality assurance standards which must be met if a product is to be sold on the European 
market,  and  the  related  Commission  Decision  of  15  April  2004  on  an  Intra-Community 
transfer  of  explosives  document,  which  contains  a  number  of  requirements  for  the 
transportation of explosives as well as an online document which must be completed by firms 
wishing to transfer explosives. 

Other relevant legislation includes the draft Directive on the identification and traceability 
of  explosives  and  the  legislation  related  to  ADR  which  includes  specific  provisions  on 
explosives. At national level, all EU Member States have transposed the Directives related to 
explosives  for  civil  use.  The  majority  of  Member  States  have  elaborated  legal  and  practical 
arrangements  regarding  the  licensing  or  explosives  and  record-keeping  requirements, 
requiring registration, applications for approval and introduction of security measures onsite. 

2.2.4.  Detection 

2.2.4.1.  Specific problems 

The following specific problems can be identified: 

•  Detection  technologies  and  devices  cannot  detect  all  explosives  and  explosives 

precursors. 

•  Detection  technologies  and  devices  do  not  always  perform  in  line  with  the 

indications given by their manufacturers. 

•  People  purchasing  and  working  with  detection  technologies  and  devices  are  not 

sufficiently aware of the possibilities and limitations of these instruments. 

•  Detection  technologies  and  devices  are  not  always  used  in  a  strategic,  targeted 

manner. 

•  Member  States  exchange  little  information  on  the  quality  and  performance  of 
detection equipment and undertake testing, trialling and certification in ‘isolation’. 

•  There  are  weaknesses  in  the  EU  knowledge  triangle.  Research  ideas  may  not 

become innovations and it is difficult, at best, to get new products to market. 

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2.2.4.2.  Scale of the problems and existing action 

Detection is, in a sense, the last remedy where prevention activities have failed or have been 
circumvented. Detection tools should help to minimise the risks of terrorists using explosives. 
Efficient  and  accurate  explosive  detection  tools  are  therefore  necessary  to  increase  the 
chances that explosives and substances that can be used to become explosives are identified. 
Important  issues  to  be  addressed  in  this  regard  are:  overall  improvement  of  detection 
technologies  and  their  use  by  operators;  the  identification  of  priority  areas  to  improve  the 
strategic  and  targeted  use  of  detection  tools;  and  lack  of  EU  cooperation  /  coordination 
leading to single market obstacles; and difficulties to roll out new solutions and technologies 
stemming from research onto the market. 

The main groups of end-users on the market are: 

•  Airports, ports, railway stations and railway operators (passengers) 

•  Freight transporters, warehouses and logistic centres 

•  Government  and  public  agencies:  government  buildings,  courthouses,  public 

stadiums, border crossings 

•  Financial institutions 

•  Operators of critical infrastructure (electricity, oil & gas networks, refineries) 

A  great  number  of  European  public  and  private  actors  are  purchasing  explosives  detection 
equipment they did not have in the past, but there is also a necessity to replace and/or upgrade 
equipment regularly. The turnover time of such equipment is considered to be on average 3-5 
years. 

Improvement of detection technologies and their use 

Knowledge  on  the  performance  of  existing  equipment  and  their  use  should  be  further 
improved. Detection technologies and devices may never be able to detect all explosives and 
all  explosives  precursors  imaginable.  Especially  the  use  of  the  latter  to  make  IEDs  is  a 
relatively new phenomenon. Further, operators can miss suspicious objects even if they had 
been  correctly  screened.  The  effective  use  of  screening  tools  require  overall  very  high  skill 
levels and expertise of the operators. 

Finally,  end-users  do  not  always  employ  updated,  combined  detection  equipment.  The 
detection of explosives is more effective if the technologies are combined. This is sometimes 
not done appropriately. Private operators of freight and/or passenger transport infrastructure, 
lacking  the  necessary  funds,  are  not  always  able  to  install  combined  systems  that  can  be 
further upgraded over time. 

The identification of priority areas to improve the strategic and targeted use of detection tools 

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In addition to the issues related to the reliability and performance of detection tools, there is 
the challenge of placing the right equipment at the right place. Detection systems in the EU 
range  from  relatively  ‘common’  types  like  X-ray  machines  and  sniff  dogs  to  more 
sophisticated  technologies  such  as  EDS  machines,  vapour  detection,  robots  and  biological 
detection  systems.  Most  use  these  technologies  at  (Schengen)  airports  and  harbours.  Some 
countries have mobile detection units and can therefore make tactical use of their equipment. 
Especially  those  Member  States  with  external  borders  refer  to  the  use  of  detection 
technologies  at  border  control  posts.  Member  States  are  increasingly  considering  extending 
the coverage of these technologies to new locations, such as conference venues, railway and 
underground stations and other public facilities.  

The demand for detection systems, as discussed above, has risen substantially in all areas /for 
all groups of end users. The costs of the equipment are considerable. For example, automated 
baggage  control  screening  devices  at  airports  can  cost  up  to  €1  million  each  (with  a  bags 
throughput  of  900-1200  pieces  per  hour  (slower  machines  are  less  costly,  but  have  a  much 
lower throughput). Smaller trace detection equipment may cost from €30,000 to 50,000, with 
a  throughput  of  30-60  bags  per  hour.  Some  personal  detection  tools  that  are  considered 
relatively  reliable  (e.g.  CAT)  are  slower,  and  do  not  allow  for  a  quick  trespassing  of 
passengers.  As  already  mentioned,  detection  is  most  effective  when  using  a  combination  of 
solutions, thus making it necessary for users to purchase several tools.  

From the above it is clear that, simply from a cost perspective, there is a limit to the amount 
of detection tools that can be  purchased and installed. It is important to map and assess the 
detection needs and prioritise the placement of detection equipment. At present, often public 
and  private  users  seem  to  have  adopted  a  rather  ad-hoc  approach,  placing  equipment  where 
the  need  seemed  highest  in  order  to,  for  example,  comply  with  new  legislation,  address 
detection gaps and respond to (perceived) threats or real incidents. 

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Lack of EU cooperation / coordination leading to Single Market obstacles 

The development and acquisition of detection solutions is a complicated and highly expensive 
endeavour.  With  the  exception  of  some  good  practice  in  the  aviation  sector  Member  States' 
authorities  that  are  purchasing  detection  equipment  often  have  to  rely  entirely  on  the 
information provided by the producers and on the views of those few other actors, perhaps in 
other countries or other sectors, that have used the same or similar equipment. Each detection 
solution  has  to  go  through  some  form  of  nationally  carried  out  testing  and  certification 
procedure,  which  is  often  lengthy  and  complex.  Suppliers  of  detection  solutions  also  face 
various obstacles. New demands for the detection of an ever increasing number of explosives 
and specific substances in ever smaller quantities require substantial research and innovation. 
In  an  industrial  sector  reigned  by  confidentiality  (if  criminals  or  terrorist  would  know  what 
substances  detection  tools  can  identify  this  would  defeat  the  purpose  of  the  tool)  producers 
find it difficult to meet the specific needs of their clients. In order to sell their solutions, they 
have to go through testing and certification procedures which vary from country to country. 

This  ambiguity  in  the  results  sheds  light  on  the  problems  in  the  market  of  such  devices:  a 
major problem with detection equipment is that there is no common and reliable certification 
and testing in place in Europe. With the exception of detection for aviation purposes, there are 
no  minimum  requirements  at  EU  level  on  the  core  features  of  the  systems,  e.g.  what 
explosives  should  trace  detection  equipment  identify,  or  what  is  the  allowed  probability  of 
false  signals?  This  unclear  situation  constitutes  an  obstacle  to  the  functioning  of  the  Single 
Market. 

2.3.  Who is affected, in what ways, and to what extent? 

The entire EU society is affected by the identified high level problem as terrorists may strike 
anywhere and at any time. The availability of explosives and explosives precursors, and the 
open nature of internal EU borders mean that any EU Member States can be the subject of a 
terrorist threat. 

The problem potentially affects all European citizens, inhabitants of the European Union, the 
Member  State  governments  and  the  European  Union  as  a  whole.  Effects  can  be  both  direct 
(e.g. casualties following a terrorist attack) and indirect (e.g. the disruption of certain services 
following, psychological damage). 

2.4. 

How would the problem evolve, all things being equal?  

The situation within the EU would continue evolving based on trends applicable today: 

•  Certain  Member  States  would  address 

issue 
comprehensively because of a history of terrorist attacks or because of a perceived 
threat; 

the  explosives 

security 

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•  Certain  Member  States  would  address  the  explosives  security  issue  only  to  a 
certain  limited  degree  due  to  the  fact  that  they  would  not  feel  threatened  by  the 
possibility of terrorist attacks; 

•  Information exchange would take place on an ad hoc basis; 

•  Informal networks would continue to be built. 

The  above  trends  would  generally  improve  the  explosives  security  situation  within  the  EU 
only  marginally.  Due  to  the  free  movement  of  goods  and  people  within  the  EU  and  open 
internal  borders  there  would  continue  to  be  a  high  risk  that  dangerous  materials  could  be 
acquired and used with malicious intent. The lack of a detailed strategy and action plan at EU 
level would constitute a lost chance in combating terrorism. 

2.5. 

Does the EU have the right to act? 

2.5.1.  General considerations 

The use of explosives to harm innocent citizens has been the most common method used by 
terrorists  to  instil  fear  in  populations  accustomed  to  living  in  democratic,  free  and  open 
societies.  In  October  2003  the  JHA  Council  had  concluded  there  was  no  need  to  introduce 
new  measures  on  storage  and  transport  of  explosives.  However,  in  the  aftermath  of  the 
terrorist  bombings  in  Madrid  on  11  March  2004  a  consensus  started  to  emerge  within  EU 
Member  States  for  the  need  to  explore  a  more  harmonised  system  that  would  prevent 
explosives, detonators, bomb-making equipment and fire-arms from falling into the hands of 
terrorists. In its 25 March 2004 Declaration, the European Council recognised the “need to 
ensure  terrorist  organisations  and  groups  are  starved  of  the  components  of  their  trade”.  In 
particular  it  recognised  “the  need  to  ensure  greater  security  of  firearms,  explosives,  bomb-
making  equipment  and  the  technologies  that  contribute  to  the  perpetration  of  terrorist 
outrages”. Furthermore, the revised Plan of Action on Combating Terrorism of June 2004 
called  upon  the  Council  and  the  Commission  to  examine  the  scope  for  measures  to  ensure 
greater security of explosives (Action 3.6.1). 

The  Commission,  in  its  October  2004  Communication  on  Prevention,  preparedness  and 
response to terrorist attacks4 signalled its intention to present proposals if necessary to ensure 
the highest possible security level in Europe. Indeed, the “Hague Program - Strengthening 
freedom, security and justice in the EU”, endorsed by the European Council in November 
2004,  explicitly  invites  the  Commission  to  make  proposals  aimed  at  improving  the  storage 
and  transport  of  explosives  as  well  as  at  ensuring  traceability  of  industrial  and  chemical 
precursors.  

Nevertheless, for each of the measures proposed by the ESETF, considerations of subsidiarity 
and  proportionality  need  to  be  considered  separately  –  in  other  words,  no  action  should  be 

4 

COM(2004) 698, 20.10.2004. 

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taken forward at the EU level unless there are good reasons for doing so. Although within the 
context of the Impact Assessment Report it would go too far to explicitly deal with this issue 
for all of the proposed actions, the following sections aim at clarifying this point for the main 
groups of proposed actions. 

2.5.2.  The added value of the European Union 

The European Union is an area of increasing openness and an area in which the internal and 
external aspects of security are intimately linked. It is an area of increasing interdependence, 
allowing for the free movement of people, ideas, technology and resources. As a result it is 
also an area which terrorists may abuse to pursue their objectives and which has already been 
abused for this purpose. The foiled attacks in London and Glasgow on the 29th and 30th of 
June were a reminder of the threat. In this context concerted and collective European action, 
in the spirit of solidarity, is indispensable to combat terrorism.  

The added value of the European Union in the explosives security field stems from the role of 
the EU in facilitating cooperation, funding and legislation. 

2.5.2.1.  The EU as a catalyst for cooperation 

There  is  a  clear  need  for  cooperation  at  the  EU  level  to  co-operate  to  combat  terrorism. 
Terrorism  is  international  in  character,  the  EU  has  shared  borders  and  some  terrorists  can 
move  freely  within  the  EU.  There  is  a  strong  emphasis  in  the  proposed  Action  Plan  on 
measures  involving  cooperation  between  Member  State  authorities  and  other  stakeholders. 
The EU is well placed to lead and to act as a catalyst for this cooperation. In some cases the 
cooperation concerns the exchange of experience and good practice and in others it involves 
the  exchange  of  intelligence  that  could  have  operational  significance.  These  actions  could 
themselves help reinforce channels for bilateral and multilateral cooperation between Member 
States.  Member  States  are  not  all  equally  affected  by  the  problems  of  terrorism.  In  some 
instances  cooperation  may  only  need  to  involve  clusters  of  Member  States  facing  similar 
challenges. At the same time international cooperation needs to co-operate extend beyond the 
EU and some of the actions will involve EU level agencies in this cooperation. Examples of 
actions involving cooperation at EU level include:  

•  The early warning system; the detection related scenarios and matrix; 

•  The bomb data system; 

•  The database on explosives;  

•  The conferences/events on the security of explosives; 

•  The network of experts on detection of explosives; 

•  The EOD network; and 

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•  The dissemination of research results. 

For all of these measures the added value of EU action is clearly demonstrated – in fact the 
international  character  of  these  measures  is  the  core  of  what  makes  them  effective.  Co-
operation between law enforcement authorities and exchange of relevant information are all 
covered under Title VI of the Treaty on European Union. The process of the development of 
the  Action  Plan  has  itself  been  a  cooperative  process  involving  a  blend  of  Member  State 
experts and stakeholders. 

Another  example  of  enhanced  co-operation  which  does  not  immediately  require  legislative 
action  can  be  found  in  the  area  of  detection.  Here  the  rationale  for  EU  involvement  is 
particularly clear – if agreement can be  found on the  standards  and testing and certification 
schemes for detection equipment, this will benefit all suppliers of such equipment, since they 
will  no  longer  have  to  ensure  that  their  equipment  meets  different  standards  imposed  by 
different  Member  States.  For  the  public  authorities,  the  benefits  will  be  that  they  can  be 
assured  that  detection  levels  can  be  evaluated  and  compared  much  better,  thus  increasing 
possibilities for comparison and exchange of best practices. 

2.5.2.2.  The EU as a provider of funding for actions 

Some  of  the  actions  in  the  Action  Plan  involve  EU  expenditure.  The  cooperation  activities 
will require EU funding. The actions concerning EU level research will require EU funding 
(FP7  and  Crime  Prevention  Programme)  but  normally  on  a  co-funded  basis.  These 
programmes have all been adopted on a separate legal basis and they pursue EU wide goals 
established together with the Member States. Some financial support is likely to be required 
to stimulate the testing and trialling of detection equipment and systems. Normally such costs 
would be met by the producers of such equipment. However, there is a strong public policy 
interest  in  ensuring  that  detection  equipment  and  systems  work  in  practice.  There  may  be 
circumstances  in  which  valid  conditions  for  trialling  and  testing  can  only  be  created  by  the 
public  sector.  There  may  also  be  a  strong  case  for  keeping  performance  data  on  detection 
equipment  and  systems  confidential  to  the  public  sector,  in  which  case  it  would  be 
unreasonable for manufacturers and suppliers to fund the testing and trialling. The advantage 
of co-funding from the EU is that the results could inform the strategies and tactics of security 
agencies across Europe.  

2.5.2.3.  EU legislation 

Twelve  of  the  actions  potentially  involve  the  use  of  EU  legislation.  Where  this  is  the  case, 
such  actions  will  themselves  have  to  be  subject  to  Impact  Assessment,  which  will  have  to 
provide further information on the EU's right to act and the legal basis for doing so. Without 
going into the detail, it is clear that in some cases the ‘normal’ rationales for EU legislation 
will  apply.  For  example,  there  is  a  ‘single  market’  rationale  for  the  adoption  of  EU  wide 
security measures for explosives manufacturers as well as a security rationale (the EU safety 
standards  for  explosives  have  in  large  part  a  single  market  rationale).  Similarly,  the 
harmonisation  of  EU  requirements  for  the  licensing  and  handling  of  large  amounts  of 
pyrotechnic  articles  could  have,  in  part,  a  single  market  rationale.  Other  actions  are  closely 

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linked  to  existing  legislation  for  example,  regulation  concerning  the  transport  of  explosives 
and  EX/II  and  EX/III  vehicles.  It  should  be  emphasised  here  that  many  of  these  topics  are 
already  regulated  to  some  extent  by  EU  legislation,  as  mentioned  above  in  Section  2.2.3.2. 
(such as Council Directive 93/15/EEC on the harmonisation of the provisions relating to the 
placing on the market and supervision of explosives for civil uses, Commission Decision of 
15 April 2004 on an Intra-Community transfer of explosives document, the draft Directive on 
the identification and traceability of explosives, the legislation related to ADR which includes 
specific provisions on explosives and the recent EU directive on pyrotechnic articles, which 
was adopted by Council on 16 April 20075. There are other actions where legislation may be 
required  but  where  the  rationale  is  principally  to  improve  security.  In  these  cases,  careful 
account  will  need  to  be  taken  of  the  potential  economic  costs  that  could  accrue  and  the 
challenges of enforcement. In addition, further simplification of legislation should be pursued 
whenever possible. 

2.5.3.  Proportionality 

The assessment of proportionality of public policy to combat terrorism is extremely difficult. 
The  arbitrary  and  apparently  irrational  nature  of  terrorism  means  that  its  threat  and 
consequences have a disproportionate effect on EU citizens. The fear generated is strong and 
induces indirect damage to wellbeing way beyond the direct costs of loss of life, injury and 
property. The reactions of security agencies to terrorism can themselves induce massive costs 
and inconvenience on EU citizens. In these circumstances the vast majority of the actions in 
the preferred option are considered to be proportionate. The cautious approach recommended 
towards those actions where the benefits are uncertain and could potentially be outweighed by 
the indirect costs they could induce, will ensure that the preferred option is proportionate. 

2.5.4. 

Subsidiarity 

The development of the Action Plan has been undertaken in cooperation with Member States 
and  the  actions  are  anticipated  to  command  strong  support  from  them.  Most  of  the  actions 
either  require  action  at  the  EU  level  or  involve  the  encouragement  and  facilitation  of 
approaches  where  there  would  be  benefit  in  implementation  following  a  similar  path 
throughout the EU. Responsibility for security will continue to reside at Member State level 
but  there  is  a  strong  recognition  amongst  Member  States  that  where  they  have  developed 
effective  means  to  address  the  problems  of  explosives,  they  too  would  benefit  from  other 
Member States learning from this experience and where appropriate cooperating and adhering 
to common approaches. 

The  subsidiarity  principle  is  satisfied  as  the  measures  being  undertaken  through  the  EU 
Action  Plan  cannot  be  achieved  by  any  single  EU  Member  State  and  must  therefore  be 
addressed at EU level.  

5 

Directive 2007/23/EC (OJ L 154, 14.6.2007, p. 1). 

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Fundamental  rights  are  not  affected  by  the  EU  Action  Plan.  Any  potential  interplay  will 
however be analysed in detail when taking up concrete actions under the Action Plan.  

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3. 

OBJECTIVES 

The  objective  of  an  EU  Action  Plan  on  Enhancing  the  Security  of  Explosives  would  be  to 
identify and prioritise actions that should be undertaken at EU level and actions that should be 
taken forward jointly by Member States, in order to combat the use of explosives by terrorists 
within the EU.  

Such  an  EU  Action  Plan  would  cover  explosives  that  are  manufactured  legitimately  and 
illicitly. It would include measures organized under four strategic pillars: 

•  Horizontal  Measures  –  aimed  at  improving  exchanges  of  information,  the 

development of threat assessments and research.  

•  Prevention  Measures  –  focusing  on  awareness  raising,  control  and  regulation  of 
precursors, increased control on the market of explosives and pyrotechnic articles, 
vetting  and  security  measures  in  explosives  facilities  and  transport  and  internet-
related actions.  

•  Detection  Measures  –  proposing  scenarios,  minimum  standards,  exchanges  of 
information and EU-wide certification, testing and trialling schemes for detection 
tools.  

•  Preparedness  and  Response  Measures  –  including  the  establishment  of  an  EOD 
network  and  liaison  with  mobile  telephone  providers  on  the  shutting  down  of 
antennas. 

The following general, specific and operational objectives can be set for the Action Plan. 

•  General objective:  

GO  To reduce the number and potency of terrorist and other criminal incidents in 

the EU using explosives.  

•  Specific objectives:  

SO1  To  prevent  the  use  of  legitimately  and  illicitly  manufactured  explosives  by 

terrorists and other criminals; 

SO2  To increase the constraints on the illicit manufacture of explosives by terrorists 

and other criminals; 

SO3  To  reduce  the  reliability  and  potency  of  ‘home  made’  explosives  or 

components manufactured by terrorists and other criminals; 

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SO4  To increase the probability of detection of terrorists and other criminals illicitly 

handling and using explosives and precursors; 

SO5  To reduce the smuggling of explosives into the EU destined for illicit use by 

terrorists and other criminals; 

SO6  To  increase  the  chances  of  prevention  and  intervention  opportunities  by  law 

enforcement bodies. 

•  Operational objectives:  

–  To  reduce  theft  by  and  the  sale  of  explosives  to  (potential)  terrorists  and  other 

criminals; 

–  To  reduce  the  supply  and  quality  of  information  on  how  to  illicitly  manufacture 

explosives; 

–  To better monitor the illicit use of explosives and the precursors and components 

of explosives; 

–  To label explosives and the precursors and components of explosives to generate 

evidence that would lead to the conviction of terrorists and other criminals; 

–  To improve the quality of detection and enforce detection standards; 

–  To ensure that new detection solutions and technologies from research are rolled 

out on the market; 

–  To  increase  the  application  of  good  practices  that  improve  the  security  of 

explosives. 

4. 

POLICY OPTIONS 

Four policy options have been identified concerning the establishment of an EU Action Plan 
on  Enhancing  the  Security  of  Explosives.  These  options  have  been  elaborated  based  on  the 
recommendations for specific actions set fourth in the Explosives Security Experts Task Force 
(ESETF) report and group together the various ESETF recommendations depending on their 
impact: 

•  Policy Option 1 – Status Quo 

•  Policy Option 2 – Minimum Option 

•  Policy Option 3 – Intermediate Option 

•  Policy Option 4 – Maximum Option 

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The  ESETF  report  identified  specific  recommendations  for  actions  which  were  meant  to  be 
the  basis  for  the  EU  Action  Plan6.  These  measures  were  reorganised,  and  in  certain  cases 
merged for the purpose of clarity, under: 

•  An overarching heading containing measures applicable horizontally; 

•  Three strategic headings: 

–  Prevention 

–  Detection 

–  Preparedness and response 

This organisation is kept throughout this impact assessment. 

At  this  point  it  should  be  clarified  that  the  different  policy  options  and  the  packages  of 
measures contained within them have been structured in this way in order to allow discussion 
of a limited number of options only, and also to focus the discussion on those issues which are 
likely to have the most impact. The different options are cumulative – in the sense that each 
higher  numbered  option  also  contains  the  actions  in  the  lower  numbered  option(s).  This 
approach was taken to avoid the need to discuss as many options as proposed actions in the 
action  plan.  The  packages  of  possible  actions  which  have  been  included  in  the  different 
options have been construed on the basis of a prima facie assessment of their possible impact 
– in order to ensure that the measures which can be implemented easily and quickly would in 
any  case  be  included  in  the  Action  Plan,  and  proposals  on  which  more  discussion  could  be 
expected would feature in the more elaborate options. 

4.1. 

Policy Option 1 – Status Quo 

The first Policy Option implies that no changes are made to the current situation. All actions 
included  are  already  underway  or  are  planned  to  happen  even  in  the  absence  of  the  Action 
Plan. The Status Quo is a combination of existing organisations responsible for the provision 
of  strategic  assessments  on  counter-terrorism  matters,  a  research  package  which  includes 
allocations  related  to  the  security  of  explosives,  a  legislative  acquis  concerning  aviation 
security,  transport  of  dangerous  goods  and  the  development  of  the  single  market  of  civil 
explosives and draft legislation in the area of the traceability of explosives for civil use and 
harmonisation of criminal sanctions on distributing bomb-making experience on the internet. 

It should be mentioned that measures also exist at national level. These relate to all aspects of 
explosives  security,  ranging  from  public  security  aspects,  precursors,  supply  chain  and 
detection.  However,  as  mentioned  in  section  2  –  problem  definition,  the  approaches  vary 
greatly across the EU, with some Member States applying high explosives security standards 

6 

The list of ESETF recommendations is found in Annex 2. 

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in  nearly  all  areas  and  others  having  relatively  underdeveloped  security  systems  and 
mechanisms. 

OPTION 1 – STATUS QUO 

Horizontal measures 
Improve the exchange of timely information and best practice 
Europol and Eurojust 
Strengthen explosives related research  
Current FP7 research with regard to detection and public security (e.g. Security Research Call, 1 of Dec 2006) 
Prevention measures 
Improve the control over explosives available on the market and pyrotechnic articles 
Implementation of the Traceability Directive (recommendation 227) 
Directive on explosives for civil use 
Reduce the supply and quality of information on how to illicitly manufacture explosives 
Harmonize criminal sanctions for distributing bomb-making experience over the Internet (recommendation 41.) 
Improve the security of transport of explosives 
ADR legislation and working group on transport 
Detection Measures 
EU legislation in the area of aviation security 

4.2. 

Policy Option 2 – Minimum Option 

The  second  Policy  Option  includes  a  variety  of  measures  which  together  form  a  ‘package’ 
combining  horizontal  measures,  prevention  initiatives,  detection  measures  and  actions  to 
increase preparedness and readiness to respond. Based on broad consultations, it is anticipated 
that a majority of stakeholders would consider these actions ‘acceptable’ and beneficial, with 
relatively low costs and risks. The Policy Option has a strong focus on: 

•  Exchanging information, knowledge and experience, both vertically and horizontally 

The  option  includes  several  proposals  for  the  establishment  of  cooperation  and 
coordination  mechanisms  in  the  shape  of  databases,  events,  expert  groups  and 
networks.  Together  these  would  form  the  knowledge  and  intelligence  base  of  the 
Action Plan. The actions proposed do not only concern the horizontal, EU level, but 
also affect the national level. 

•  Further existing and launching new research 

Several  of  the  actions  include  research  into  new  areas  and  expanding  research  in 
already existing areas. Most have a very practical focus, linking the themes to other 
concrete actions. For example, the research proposed with regard to the detection of 
IEDs at airports will feed into the actions aimed at improving detection technologies 
overall.  

7 

This number as well as other numbers in the tables contained in section 4 are references to the concrete 
recommendations for actions put forward in the ESETF report. 

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•  Awareness-raising and alerting options in the precursors supply chain 

Recent  events  have  once  more  showed  the  importance  of  making  all  actors  in  the 
supply  chain  of  precursors  and  explosives  more  aware  of  the  potential  risks  and 
suspicious transactions. The option includes several actions that relate to campaigns 
and the development of alert mechanisms. 

•  Assessments and feasibility studies whether further measures should be undertaken 

The  option  also  includes  several  actions  aimed  at  assessing  the  feasibility  and 
launching  debates  on  some  of  the  more  ‘challenging’  initiatives  which  would  be 
included in the Action Plan. As for the actions that focus on research, they are meant 
to feed into actions with a more ‘operational’ focus. 

•  Some additional security and detection measures 

Finally, the option includes a limited number of actions with an ‘operational’ focus, 
covering the security of facilities and detection. 

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OPTION 2 - MINIMUM OPTION 

Horizontal measures 
Improve the exchange of timely information and best practice 
Establish an Early Warning System (recommendation 39. and 40.) 
Regularly organise an event on the security of explosives (recommendation 50.) 
Develop threat assessments 
Consider developing specialised threat assessments (no number in ESETF report) 
Strengthen explosives related research  
Improve the aggregation and spread of research results (recommendation 49.) 
Perform  further  research  on:  1  –  IEDs;  2  -  Chemicals  found  at  an  investigation  scene;  3  -  Detection  of  explosives  and 
precursors; and 4 - Mobile explosives kits (recommendation 47.) 
Perform further research concerning the detection of Improvised Explosive Devices at airports, land and maritime locations 
(recommendation 31.) 
Perform further research to find inhibitors which could be added to precursors (recommendation 48.) 
Support further research to find technical solutions to jam mobile phones (recommendation 45.) 
Prevention measures 
Improve staff awareness and alerting concerning precursors 
Public authorities to provide security information to the entire precursor supply chain (recommendation 1.) 
Simple means within supply chain to alert national authority (recommendation 2.) 
Campaigns to raise staff-awareness all along supply chain (recommendation 3.) 
Improve the control over transactions involving precursors 
Assessing  benefits  of  creating  a  scheme  for  each  precursor  handled  by  retail  sector,  under  which  all  packaging  would  be 
labelled with a code specifying subject of registration (recommendation 9.) 
Improve the control over explosives available on the market and pyrotechnic articles 
Launch debate on the need to review the classification of "desensitized" explosives (recommendation 19.) 
Improve the security of explosive facilities 
Effective Security Plans/Security Management Systems at all facilities (recommendations 12. and 14.) 
Detection Measures 
Establish scenario based approach to identifying work priorities 
Setup of a working group to develop scenarios and to identify technology requirements (recommendation 23.) 
Create matrix of what is desired and currently possible in each scenario (recommendation 24.) 
Developing minimum detection standards 
Develop  mechanisms  for  the  identification  and  dissemination  of  good  practice  in  detection  systems  and  use  of  detection 
equipment (part of recommendation 25.) 
Improving the exchange of information 
Ensure that security staff are provided with up-to-date information on new terrorist modi operandi (recommendation 42.) 
Assess and improve where necessary the situation as regards the availability of training data and other information/feedback 
for manufacturers of detection solutions (recommendation 30.) 
Create an end-user focused handbook concerning detection (recommendation 33.) 
Create a network of experts on the detection of explosives (recommendation 34.) 
Establish EU-wide certification, testing and trialling schemes 
Develop mechanisms for the identification and dissemination of good practice in detection systems and the use of detection 
equipment (part of recommendation 27.) 
Assess the need for the development of standards concerning certification, testing and trialling processes (recommendation 
29.) 
Improve the usage of detection technologies in specific locations 
Improve  and  support  the  use  of  detection  technologies  at  airports,  railway  stations  and  other  public  facilities 
(recommendation 31.) 
Preparedness and response measures 
Improve the exchange of information and best-practices among relevant Member State authorities 
Establish a European EOD Network (recommendation 38.) 

4.3. 

Policy Option 3 – Intermediate Option 

The  third  Policy  Option  is  again  a  mix  of  horizontal  measures,  prevention  initiatives, 
detection  measures  and  actions  to  increase  preparedness  and  readiness  to  respond.  There  is, 
however, a relatively higher focus on actions in the area of prevention. This option includes 

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all actions under Policy Option 2 with the addition of additional actions deemed to be more 
sensitive in nature and requiring bigger efforts for implementation.  

The overall focus of Policy Option 3 is more operational, with a set of measures built around: 

•  Regulation of new areas and updating regulatory arrangements in others 

•  Several  actions  focus  on  addressing  areas  which  are  currently  insufficiently 
covered or not addressed at all, such as vetting of staff working with explosives, 
the  precursors  market  and  raw  materials  used  to  manufacture  explosives.  Other 
actions  may  not  result 
legislation  but  constitute  otherwise  binding 
requirements,  such  as  the  obligation  for  Member  States  to  keep  explosives 
manufacturers and distributors informed of regional threats. 

in 

•  Introducing EU schemes and standards 

•  In  the  area  of  detection,  the  option  proposes  the  development  of  new,  EU-wide 
schemes  to  certify  and  test  detection  solutions.  In  addition  to  increasing  the 
performance of detection systems, these are also aimed at further removing single 
market obstacles. 

•  Concrete security interventions 

•  The  option  also  presents  several  actions  with  a  practical  focus  on  improving 
existing  standards,  such  as  the  initiative  to  improve  the  security  of  Mobile 
Explosive  Manufacturing  Units  (MEMUs)  and  of  EX/II  and  EX/III  vehicles 
carrying explosives. Others focus on mobile phone networks and the Internet. 

OPTION 3 - INTERMEDIATE OPTION 
Horizontal Measures 
Improve the exchange of timely information and best practices 
Create a European Bomb Data System (recommendations 35.,36. and 37.) 
Prevention Measures 
Improve the regulation of explosives precursors available on the market 
The establishment of a system concerning the regulation of explosives precursors available on the market 
(recommendation 4.) 
Improve the control over explosives available on the market and pyrotechnic articles 
Ensure that each Member States has formal systems for authorising, regulating and licensing the manufacture, storage, sale, 
use and possession of explosives including by private persons (recommendation 21.) 
Improve the security of explosives facilities 
Introduce an obligation for the relevant national authorities to keep explosives manufacturers and distributors informed as to 
the regional threat at all times (recommendation 13.) 
Raw materials used in the manufacture of bulk explosives and finished product should be periodically accounted for and 
reconciled as approved by the National Authorities (recommendation 20.) 
Improve the security of Mobile Explosive Manufacturing Units (MEMUs) (recommendation 15, 16, 17.) 
Improve the security vetting of personnel 

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All personnel employed in the manufacturing, storage, distribution and use of explosives should be vetted and hold a formal 
authorisation to have access to explosives (recommendation 11.) 
Improve the security of transport of explosives 
All EX/II and EX/III vehicles carrying explosives should be equipped with certain security enhancement solutions 
These security solutions include (recommendation 18.): 
1) be fitted with 24 hour remote monitoring systems 
2) be capable of immobilising the engine remotely if safe and applicable subject to the Vienna Convention 
3) be fitted with an anti theft system. 
4) have sufficiently secure compartments 
5) be fitted with a means of communication 
6) have a recognised marking affixed to the roof of the vehicle 
Reduce the supply and quality of information on how to illicitly manufacture explosives 
Part of 41: Limit the spread of bomb-making experience over the internet (recommendation) 
Detection Measures 
Improving the exchange of information 
Create a database containing the specifications of explosives produced within the EU (recommendation 32.) 
Establish EU-wide certification, testing and trialling schemes 
Create a European wide certification scheme for detection solutions (recommendation 26.) 
Create a European wide testing scheme for detection solutions (recommendation 27.) 
Create a European wide trialling scheme for detection solutions (recommendation 28.) 
Preparedness and response measures 
Develop specific preparedness and response measures for terrorist threats using explosives 
Create the possibility for relevant law enforcement authorities to request providers to shut down mobile phone antennas in the 
case of a threat of a terrorist attack (recommendations 44. and 46.) 

4.4. 

Policy Option 4 – Maximum Option 

The  fourth  Policy  Option  is  a  mix  of  prevention  initiatives  and  detection  measures,  mainly 
addressing regulatory aspects, recording and reporting mechanisms and standardisation.  

The option includes all actions under Policy Option 3 with the addition of measures identified 
in  the  ESETF  report  which  can  be  described  as  being  very  ambitious  and  which  require 
genuine commitment to the process.  

Option 4 is ambitious, including a ‘package’ of measures focusing on: 

•  Regulation of new areas and updating regulatory arrangements in others 

•  Several  new  legislative  instruments  are  included,  such  as  the  legal  obligation  to 
record the identity of buyers of certain quantities / concentrations of precursors, a 
ban on selling precursors to minors and harmonisation of legislation in the area of 
pyrotechnic articles. 

•  Introducing EU schemes and standards 

•  New  schemes  are  proposed  for  the  recording  of  the  identity  of  the  buyers  of 
precursors,  for  reporting  on  suspicious  transactions  and  for  trialling  detection 
solutions. Minimum standards are proposed concerning the security of storage of 
explosive precursors. 

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OPTION 4 - MAXIMUM OPTION 
Prevention Measures 
Improve the regulation of explosives precursors available on the market 
Introduce a system for the recording of the identity of the buyer of precursors above certain quantities and/or concentrations 
(recommendation 7.) 
A European minimum standard and industrial guidance by way of an appropriate code concerning the security of storage of 
explosives precursors (recommendation 8.) 
Improve the control over transactions involving precursors 
Establish a system of reporting suspicious transactions (recommendation 5.) 
A binding system concerning the notification to the relevant national authority of any transactions involving the products on 
the list which can be considered suspicious (recommendation 6.) 
Introduce a complete ban on selling precursors to minors (recommendation 10.) 
Improve the control over explosives available on the market and pyrotechnic articles 
Harmonise EU requirements for the licensing and handling of large amounts of pyrotechnic articles (recommendation 43.) 
Detection measures 
Developing minimum detection standards 
Develop minimum detection standards (recommendation 25.) 

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5. 

ANALYSIS OF IMPACTS  

5.1. 

Introduction 

The four Policy Options have been assessed by considering each of the ‘actions’ in terms of: 

•  The benefits that might accrue: their contribution to the general policy objective 
and  the  six  specific  objectives.  The  benefits  have  been  summarised  through 
allocating ratings (from 0 to 5) for the general and each of the specific objectives.  

•  The financial and economic effects of each action. These have been summarised 
by  classifying  them  by  scale  and  predictability.  Six  categories  have  been  used: 
low  costs,  predicable  (less  than  500,000  Euro);  medium  costs,  predictable 
(between  500,000  Euro  and  2.0  million  Euro);  high  costs,  predicable  (above  2.0 
million);  low  costs  but  uncertain,  (where  the  action  needs  to  be  more  clearly 
defined  and  some  further  feasibility  work  will  be  required);  medium  costs  but 
uncertain; and, high costs but uncertain. The costs may be both financial costs to 
public administrations and costs that may accrue to economic actors. The financial 
costs  have  been  estimated  by  reference  to  analogous  actions  such  as  existing 
networks  and  databases  operating  at  the  EU  level.  The  estimates  are  necessarily 
approximate. 

•  The  dependence  on  other  actors  to  ensure  the  implementation  of  the  ‘actions’. 
Whilst  this  is  an  EU  Action  Plan,  in  order  to  realise  the  benefits  of  the  actions 
many non EU level actors would need to be engaged in implementation. Arguably 
the need to engage others increases the uncertainty that benefits might be realised.  

•  The potential effects on fundamental rights. These effects are described for each 

action, where such an effect may exist. 

•  The  potential  environmental  effects.  As  for  fundamental  rights,  these effects  are 

only described where they are likely to be significant. 

•  The need to change or develop EU legislation. As for the fundamental rights and 
the  environmental  effects,  these  are  only  mentioned  where  such  need  is 
anticipated.  In  a  number  of  cases  the  need  for  EU  legislation  is  a  distinct 
possibility, but may not be required.  

Each Policy Option and its individual actions are considered in turn. Given the high number 
of  actions  proposed,  it  is  impossible  within  the  scope  of  this  report  to  provide  individual 
assessments  of  all  actions  in  the  report  –  which  focuses  on  the  assessment  of  the  most 
important  actions.  All  of  the  individual  actions  are  however  considered  in  more  detail  in 
Annex 1.  

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5.2. 

Policy option 1 – The status quo 

5.2.1.  Assessment by action 

There are 7 ‘actions’ in this Policy Option. Each of these is only mentioned briefly here – a 
more detailed assessment is provided in Annex 1. 

5.2.1.1.  Horizontal measures 

Improve the exchange of timely information and best practices 

Strengthen explosives related research 

5.2.1.2.  Prevention measures 

Ensure  the  identification  and  tracing  of  explosives  based  on  the  system  proposed  in  the 
Commission  Directive  on  the  identification  and  traceability  of  explosives  for  civil  use 
(Traceability Directive). 

Council Directive 93/15/EEC on the harmonisation of the provisions relating to the placing 
on the market and supervision of explosives for civil uses 

ADR legislation and working group on transport 

Harmonise criminal sanctions for distributing bomb-making experience over the Internet 

5.2.1.3.  Detection measures 

EU legislation in the area of aviation security 

5.2.2.  Overall assessment of Policy Option 1 

The  first  policy  option  includes  7  actions  which  are  likely  to  be  implemented  regardless  of 
whether an EU Action Plan is developed. The 7 actions would most likely have a relatively 
small effect on the general objective of reducing the number and potency of terrorist incidents 
using explosives. This would be so because the measures would not address the core of the 
problem which is the availability and easy access to explosives and explosive precursors.  

The fact that terrorist attacks using explosives have been committed in the EU in recent times 
confirms that existing measures and initiatives may be insufficient. 

5.3. 

Policy option 2 – Minimum option 

5.3.1.  Assessment by action 

There  are  24  ‘actions’  in  this  Policy  Option.  Each  of  these  is  briefly  considered  in  turn.  A 
more detailed assessment is provided in Annex 1. 

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5.3.1.1.  Horizontal measures 

Establish an Early Warning System (recommendations 39. and 40.) 

The system would mainly help to increase the chances of preventing the use of explosives as 
it would ensure direct and continuous exchanges of information and coordination between the 
Member States as to threats, thefts, suspicious transactions and new modi operandi.  

Regularly organise an event on the security of explosives (recommendation 50.) 

The  events  would  help  to  increase  the  overall  knowledge  on  the  security  of  explosives  and 
enable networking between all stakeholders in the field. There would be scope for involving 
other,  more  focused,  networks  (e.g.  the  detection  experts,  EOD  units)  that  are  active  in  the 
field.  

Consider developing specialised threat assessments (no number in ESETF report) 

It  is  difficult  to  identify  the  benefits  or  the  potential  financial  and  economic  effects  of  this 
action without  additional details as to  what the action will cover. If its concerns specialised 
assessments on the threat of explosives, it would help to increase the chances of prevention 
and  intervention  and  help  to  reduce  the  number  and  potency  of  terrorist  and  other  criminal 
incidents in the EU using explosives. 

Improve the aggregation and spread of research results (recommendation 49.) 

The  action  would  help  to  increase  the  overall  knowledge  in  the  field  of  explosives  security 
and  avoid  overlaps  and  duplication  of  research  efforts.  This  would  have  an  overall  positive 
impact  on  the  objective  to  reduce  the  number  and  potency  of  terrorist  and  other  criminal 
incidents in the EU using explosives. 

Perform  further  research  on:  1  –  IEDs;  2  -  Chemicals  found  at  an  investigation  scene;  3  - 
Detection of explosives and precursors; and 4 - Mobile explosives kits (recommendation 47.) 

Further  research  would  have  a  positive  impact  if  it  is  targeted  at  exploring  and  developing 
methods  for  testing  and  trialling  practical  solutions  to  reduce  the  use  of  explosives  and 
explosives precursors by terrorists and other criminals. Research in the area of IEDs is very 
useful as there is little literature and research undertaken on this type of explosives which is 
being increasingly deployed. Research into chemicals found at an investigation scene is also 
necessary, as shown by the fact that after the 7/7 2005 attacks in London, it took more than 
two weeks to make the sites to be investigated safe to enter. Research into detection is useful, 
but what is equally important is to ensure the roll out of the results to the market. Finally, with 
regard  to  the  mobile  kits,  some  may  already  be  in  use  and  research  should  focus  on  their 
further development. 

Perform  further  research  to  find  inhibitors  which  could  be  added  to  precursors 
(recommendation 48.) 

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Provided the action builds on ongoing and past research, it could help to increase constraints 
on  illicit  manufacture  of  explosives  and  prevent  their  use  by  terrorists  and  criminals,  by 
reducing the number of precursors that can be used to produce IEDs. Various actors from the 
chemical industry have stressed that it is very difficult to identify inhibitors which would not 
affect the performance of the precursors especially in the case of precursors for industrial use. 

Perform  further  research  concerning  the  detection  of  Improvised  Explosive  Devices  at 
airports, land and maritime sites (recommendation 31.) 

Especially  in  the  light  of  their  increased  use,  research  to  enable  a  better  detection  of  IEDs 
would certainly be beneficial to prevent the use of explosives by terrorists and criminals and 
to increase the probability of detection. It would be a very challenging task as it implies the 
identification of an extremely large number of substances. 

Support further  research to find technical solutions to jam mobile phones  (recommendation 
45.) 

When  considering  that  mobile  phones  have  been  used  several  times  to  set  off  explosives, 
research to better understand how to jam mobile phones in a safe and secure way would help 
to  reduce  the  number  of  terrorist  and  other  criminals  using  explosives  in  the  EU  and  the 
potency  of  their  attacks.  It  will  also  contribute  to  prevention  and  intervention  opportunities. 
The precise scope of the actions should be identified in more detail. 

5.3.1.2.  Prevention measures 

Public  authorities  to  provide  security  information  to  the  entire  precursor  supply  chain 
(recommendation 1.) 

National awareness-raising has already proved helpful in preventing the use of explosives by 
terrorists  and  other  criminals,  constraining  the  illicit  manufacture  of  explosives,  and 
increasing the probability of detection and of prevention and intervention.  

Simple means within the supply chain to alert national authority (recommendation 2.) 

The benefits of this action are high, as proven by ‘Operation Crevice’ where a staff member 
of a public self-storage facility realised, through a discussion with friends, that the 600 kg of 
ammonium nitrate fertilizer found could be used to develop an IED. The agricultural supplier 
who had sold the fertilizer said that the young man who had bought it had claimed it was for 
his garden, admitting however that he knew the quantity purchased was far in excess of the 
amount needed.  

Campaigns to raise staff-awareness all along the supply chain (recommendation 3.) 

It is essential that recommendations 2 and 3 are implemented together, as they depend on each 
other.  The  impact  of  recommendation  3  is  the  same  as  recommendation  2.  As  mentioned 
above, there have been instances where  public and business awareness has been decisive in 

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alerting  the  authorities  to  a  potential  conspiracy  or  intention  to  cause  an  explosion.  This 
includes  the  failed  suicide  attacks  in  2005  on  the  London  Underground  where  a  rubbish 
cleaner noted a large amount of empty acetone bottles which helped to identify the flat used 
by the bombers to make their IEDs. 

Assessing  benefits  of  creating  a  scheme  for  each  precursor  handled  by  retail  sector,  under 
which  all  packaging  would  be  labelled  with  a  code  specifying  the  subject  of  registration 
(recommendation 9.) 

The benefits of this action are not clear at this stage as the assessment may conclude that the 
creation  of  such  a  scheme  would  not  have  the  desired  effects.  It  seems  that  only  if  such 
labelling was carefully coordinated with the recording of the corresponding sales there might 
be  a  benefit.  But  it  may  prove  difficult  to  ensure  uniformity  in  the  introduction  and 
enforcement of such a system. 

Launch  debate  on  the  need  to  review  the  classification  of  "desensitized"  explosives 
(recommendation 19.) 

The debate is useful to raise awareness and to increase knowledge. Excluding these types of 
explosives from the list of dangerous goods could have a very negative effect should terrorists 
and other criminals be able to reconvert such material into potentially dangerous compounds. 

Effective  Security  Plans/Security  Management  Systems  at  all  facilities  (recommendation  12. 
and 14.) 

Pre-emptive measures will help to prevent thefts and incidents at explosives facilities, which 
have indeed occurred in the recent past. It is stressed that measures are equally important in 
countries with lower threat levels as the theft of explosives is a cross-border issue (e.g. ETA 
stealing  from  quarries  in  France).  The  action  would  bring  substantial  benefits  in  terms  of 
preventing  the  use  of  explosives  by  terrorists  and  increasing  the  chances  of  prevention  and 
intervention  opportunities  by  law  enforcement  bodies.  As  such  it  would  help  to  reduce  the 
number of terrorists and other criminals using explosives and the potency of their attacks. 

5.3.1.3.  Detection Measures 

Setup  of  a  working  group  to  develop  scenarios  and  to  identify  technology  requirements 
(recommendation 23.) 

This action is to consider at a strategic level the origin and nature of threats concerning IEDs, 
manufactured  explosives,  targets,  perpetrators  etc.  The  development  of  scenarios  will  be 
beneficial  to  ensure  the  targeted  and  strategic  use  of  detection  equipment  systems,  thus 
increasing  the  probability  of  detection  and  the  chances  of  prevention  and  intervention 
opportunities.  

Create a matrix of what is desired and currently possible in each scenario (recommendation 
24.) 

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The assessment is the same as for action implementing recommendation 23 above. The actual 
content  of  the  matrix  would  be  a  national  responsibility,  while  it  would  be  beneficial  to 
discuss how to develop the matrixes and what items to include. 

Develop  mechanisms  for  the  identification  and  dissemination  of  good  practice  in  detection 
systems and use of detection equipment (part of recommendations 25 and 27.) 

Whilst  the  industry  may  not  be  ready  for  minimum  standards  (which  are  proposed  in  the 
original  recommendation  25),  there  would  be  scope  in  first  identifying  good  practice  and 
lessons  learnt  with  regard  to  existing  detection  systems  and  standards,  for  example  in  the 
aviation sector. Such exchanges could contribute to increasing the probability of detection and 
the chances of prevention and intervention opportunities. 

Ensure  that  security  staff  are  provided  with  up-to-date  information  on  new  terrorist  modi 
operandi (recommendation 42.) 

Ensuring  that  security  staff  are  immediately  updated  regarding  any  new  terrorist  TTPs 
(Tactics,  Targets  and  Planning)  is  important  and  will  have  a  positive  impact  in  terms  of 
increasing  the  chances  of  prevention  and  intervention  opportunities,  as  shown  by  the  liquid 
explosives precursors alert started in the UK. The EWS could be used as a source. Rather than 
re-creating what already exists, it would be beneficial to carry out an audit of Member States 
to establish exactly what communication structures are already in place for the sharing of such 
information. 

Assess and improve where necessary the situation as regards the availability of training data 
and  other  information/feedback  for  manufacturers  of  detection  solutions  (recommendation 
30.) 

Feedback to manufactures is essential to enhance the quality of detection, thus increasing the 
probability  of  detection  of  terrorists  and  other  criminals  handling  and  using  explosives  and 
increasing the chances of prevention and intervention.  

Create an end-user focused handbook concerning detection (recommendation 33.) 

The handbook would provide advice to end users, in the form of a user manual on detection 
systems  in  general.  It  should  not  include  information  on  the  performance  of  the  detection 
system  that  could  be  useful  to  anyone  trying  to  avoid  explosives  material  being  detected. 
Regular updates would be required, and for this purpose it may be best to use a virtual tool.  

Create a network of experts on the detection of explosives (recommendation 34.) 

The  network  of experts would increase knowledge-sharing and exchanges of experiences in 
the  area  of  detection,  thus  helping  to  increase  the  probability  of  detection  of  terrorists  and 
other  criminals  and  improving  the  chances  of  prevention  and  intervention.  Any  proposed 
networking  activity  should  be  based  on  existing  cooperation  initiatives,  where  these  are  in 
place.  

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Assess  the  need  for  the  development  of  standards  concerning  certification,  testing  and 
trialling processes (recommendation 29.) 

Especially in view of the actions that relate to the actual development of certification, testing 
and trialling schemes, this action is very useful as it would assess the need and the feasibility 
of such processes. There is little impact on the objectives through the needs assessment itself, 
but its consequences could contribute to an increase in the probability of detection of terrorists 
and other criminals handling and using explosives and explosives precursors. 

Improve  the  use  of  detection  technologies  at  airports,  railway  stations  and  other  public 
facilities (recommendation 31.) 

The precise scope of the measure should be further developed. Given the overall higher level 
of regulation and coordination, it is likely that lessons can be learned from the aviation sector. 
It is evident that overall security measures and the use of detection could be improved in other 
sectors, particularly in harbours and at ‘high-risk’ public facilities, as this would increase the 
probability  of  detection  of  terrorists  and  other  criminals  and  improve  the  chances  of 
prevention and intervention. 

5.3.1.4.  Preparedness and response measures 

Establish a European EOD Network (recommendation 38.) 

The  EOD  network  would  increase  information  and  knowledge  sharing,  through  the 
identification  of  best  practices,  the  organisation  of  joint  training  and  the  dissemination  of 
information  relevant  to  all  EOD  units.  Perhaps  more  importantly,  it  would  help  to  build 
mutual trust. It should build on existing cooperation models. Positive impacts are expected on 
objectives related to the prevention of the use of explosives by terrorists and other criminals, 
the detection of terrorists illicitly handling and using explosives and explosives precursors and 
the prevention and intervention opportunities by law enforcement bodies. 

5.3.2.  Overall assessment of Policy Option 2 

Of the 24 actions, the action judged to be most effective with respect to the overall objective 
is  the  introduction  of  security  plans  and  management  systems  at  all  explosives  facilities. 
There are five actions that are rated as ‘3’ with respect to their effectiveness in contributing to 
the  general  objective.  They  are:  establishing  an  early  warning  system:  establishing  simple 
means  within  the  precursors  supply  chain  to  alert  national  authorities  of  suspicious 
transactions;  campaigns  to  raise  awareness  of  staff  all  along  the  precursors  supply  chain; 
ensuring  that  security  staff  using  detection  equipment  are  provided  with  up  to  date 
information on terrorist modus operandi; and, establishing a European EOD network.  

Two of the actions in this Policy Option are of a character that no contribution to the general 
objective ‘to reduce the number and potency of terrorist incidents using explosives’ is likely 
to accrue immediately. Both involve the assessment of needs and preliminary investigation.  

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Together, the combination of actions in this Policy Option would contribute positively to all 
of the specific objectives. The impact would be greatest with respect to specific objective 6, 
followed  by  specific  objectives  1  and  4.  The  impact  would  be  least  with  respect  to  specific 
objective 5. 

The majority of the ‘actions’ in this Policy Option have low and predictable costs. Only 5 of 
the actions have uncertain costs and in only one case is the action anticipated to have high and 
uncertain  costs.  This  particular  action  is  the  introduction  of  security  plans  and  management 
systems at all explosives facilities which is considered to be likely to be the most effective. 
The costs are likely to accrue to in particular, users of explosives in countries where hitherto 
security standards have been relatively low. Other ‘actions’ where the costs are uncertain and 
likely  to  be  medium  are:  consideration  of  developing  specialised  threat  assessment;  and, 
campaigns to raise staff awareness all along the supply chain. The latter is assessed as being 
one of the most effective of the actions in this option.  

One action may require a change to EU legislation. Four actions may impact on fundamental 
rights. Finally, some environmental effects are anticipated as a result of 11 actions. 

The majority of actions in this Policy Option have a low dependency on non EU actors hence 
implementation should be relatively straightforward and could take place in the short term. 

5.4. 

Policy option 3 – Intermediate option 

5.4.1.  Assessment by action 

There are 14 actions in this Policy Option over and above those in Policy Option 2. Each of 
these is briefly considered in turn. A more detailed assessment is provided in Annex 1. 

5.4.1.1.  Horizontal measures 

Create a European Bomb Data System (recommendation 35, 36 and 37.) 

The creation of a European Union Bomb Data System, managed by Europol for the benefit of 
EOD and other security officials in the Member States is likely to have a positive impact, as it 
would increase information sharing and strengthen the capacity of Member States to act fast 
in response to incidents. As an example, the use of hydrogen peroxide for the bombings in the 
UK shows the potential benefits of such central information systems – if Member States have 
timely access to information on such modus operandi it may help to prevent further criminal 
use of this product and swift checks for suspicious transactions at national level. Overall, the 
action  would  contribute  to  increasing  the  probability  of  detection,  reducing  smuggling  of 
explosives (if the database logged information on incidents around the world) and increase the 
chances of prevention and intervention opportunities.  

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5.4.1.2.  Prevention Measures 

The establishment of a system concerning the regulation of explosives precursors available on 
the market (recommendation 4.) 

Especially  in  view  of  the  increased  use  of  IEDs,  in  principle,  any  of  the  issues  listed  under 
this action could have a positive impact on enhancing security, as it would reduce the ‘choice’ 
of  precursors  that  can  be  used  to  produce  such  ‘homemade’  explosives.  As  such,  it  would 
contribute to the prevention of the use of explosives by terrorists and other criminals, increase 
the constraints on their illicit manufacture and reduce their reliability and potency. The system 
will  include  the  establishment  of  a  Standing  Committee.  Further  details  of  the  system  are 
required before the wider impacts could be ascertained.  

Ensure that each Member State has formal systems for authorising, regulating and licensing 
the manufacture, storage, sale, use and possession of explosives including by private persons 
(recommendation 21.) 

Many  countries  where  there  has  been  or  continues  to  be  an  active  threat  from  terrorism 
already have strict controls on the storage, sale and possession of explosives, both commercial 
and  military.  It  is  therefore  more  a  case  of  ensuring  that  all  Member  States  adopt  the  best 
practice  found  in  these  countries.  This  would  be  beneficial  as  the  theft  of  explosives  is  a 
cross-border problem. As most of the stolen explosives have been legally produced and are of 
the  commercial  type,  often  taken  from  factories  or  mining  quarries,  most  focus  should  be 
placed  on  end  users,  as  security  measures  in  this  area  appear  to  be  lower  than  those  put  in 
place for manufacturers. The impacts would relate to the prevention of the use of explosives 
by  terrorists  and  other  criminals  and  an  improvement  of  the  chances  of  prevention  and 
intervention. 

The  financial  and  economic  costs  are  expected  to  be  medium.  Countries  that  already  have 
extensive  formal  systems  in  place  would  not  be  negatively  affected  by  this  action,  but 
authorities of countries with less developed systems may have to invest substantially. Placing 
increased security requirements on end users may entail high financial and economic costs. If 
EU-wide  requirements  were  to  be  proposed  there  may  be  a  need  to  be  a  change  of  EU 
legislation. 

Introduce an obligation for the relevant national authorities to keep explosives manufacturers 
and distributors informed as to the regional threat at all times (recommendation 13.) 

Full  awareness  of  the  level  of  threat  would  be  beneficial,  and  could  prevent  the  use  of 
explosives  and  increase  the  chances  of  prevention  and  intervention.  Regional  threat 
assessments do not exist at present and the efficacy of developing such a concept has yet to be 
proven.  Unless  there  is  a  very  specific  threat,  the  use  of  regional  alerts  is  unnecessary.  It 
should  also  be  taken  into  account  that  manufacturers  and  distributors  may  require  a  long 
response time. Threat levels are a national responsibility and various countries have different 
systems in place, it may be challenging to streamline these to ensure that response plans are 
adequate and useful for all. 

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Raw  materials  used  in  the  manufacture  of  bulk  explosives  and  finished  product  should  be 
periodically  accounted  for  and  reconciled  as  approved  by  the  National  Authorities 
(recommendation 20.) 

Little information is available on the use of raw materials in terrorist attacks. However, higher 
attention  to  these  materials  would  be  beneficial  as  they  can  be  used  to  make  bombs.  The 
action  could  therefore  prevent  the  use  of  explosives  and  increase  the  chances  of  prevention 
and  intervention.  However,  the  feasibility  of  requiring  authorities  to  take  an  active  role  in 
reconciliation and approval of quantities is likely to be low.  

It is difficult to estimate the financial and economic costs of the action. It is likely that costs 
would  be  small  in  Member  States  which  already  have  existing  high  quality  requirements  in 
place. Medium to high costs may have to be incurred by countries which have to substantially 
improve their systems, develop new procedures and allocate human resources for control and 
enforcement. 

Improve  the  security  of  Mobile  Explosive  Manufacturing  Units  (MEMUs)  (recommendation 
15, 16 and 17.) 

There  are  few  known  cases  of  thefts  of  MEMUs  and  the  benefits  of  this  measure  might 
therefore be limited. Most countries that use MEMUs have modern vehicles and good security 
measures  already  in  place.  For  example,  the  UK  has  specific  guidelines  for  MEMUs  and 
Sweden  uses  sophisticated  anti-theft  systems.  Due  to  the  potential  risk  of  theft  of  such  a 
vehicle there is scope in further improving their security. Some industrial stakeholders have 
pointed  out  that  alternative  security  measures  may  achieve  the  same  effect.  Finally,  several 
manufacturers  indicated  that  it  is  practically  impossible  to  correctly  record  the  amount  of 
explosives produced as there is always residue left in the units. 

The  number  of  MEMUs  in  the  Member  States  is  estimated  at  105.  The  financial  costs  for 
improving their security would be low, amounting to approximately 500,000 Euro, including 
their  ongoing  guarding.  There  would  be  a  possible  need  for  EU  legislation  should  it  be 
decided to integrate the requirements in transport related legislation. 

All  personnel  employed  in  the  manufacturing,  storage,  distribution  and  use  of  explosives 
should  be  vetted  and  hold  a 
to  explosives 
formal  authorisation 
(recommendation 11.) 

to  have  access 

Most Member States have vetting requirements in place for persons handling explosives. The 
UK,  for  example,  requires  a  license  for  the  acquisition  of  explosives,  while  in  Sweden  a 
license is needed for handling them. While it would be a good action to increase the security 
of  explosives,  thus  preventing  the  use  of  explosives  by  terrorists  and  other  criminals  and 
increasing  the  probability  of  detection,  prevention  and  intervention,  vetting  may  prove 
difficult to establish at a uniform level. While at present some countries carry out extensive 
background checks and psychological tests of employees, others only pay scarce attention to 
such  concerns,  often  only  requiring  a  declaration  that  the  person  in  question  has  not 
committed  any  related  crimes.  It  should  also  be  noted  that  in  the  last  10-20  years  most 

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problems with regard to staff have occurred at the ‘lower’ levels of the industry (e.g. quarries, 
construction sites) where an enormous number of people are employed, there are high levels 
of staff turnover and low vetting requirements overall. Finally, the effect of vetting could be 
questioned as it is likely that people with terrorist intentions would make sure they had a clean 
background if they wished to acquire explosives through being employed by manufacturers, 
distributors or users of explosives. 

The  financial  and  economic  costs  of  the  action  are  potentially  very  high  but  impossible  to 
estimate  at  this  stage.  Costs  for  a  single  vetting  procedure  vary  from  20  to  2000  Euro.  The 
number of persons that could be affected could run into hundreds of thousands if expanding 
the  vetting  to  sectors  such  as  construction.  It  will  therefore  be  important  to  establish  who 
should be vetted, who should carry out the vetting and who should pay for it. The economic 
effects  are  likely  to  impact  on  both  administrations  and  industries  (which  may  charge  for 
vetting).  Some  possible  fundamental  rights  issues  could  arise  depending  on  the  content  and 
criteria used for vetting and to whom the information generated were available. Principles of 
data protection and non-discrimination should in all cases be observed. 

All  EX/II  and  EX/III  vehicles  carrying  explosives  should  be  equipped  with  certain  security 
enhancement solutions (recommendation 18.) 

Thefts of such vehicles have occurred in the past and increasing their security will therefore 
have its benefits, especially in ensuring a similar level of security across the EU. The action 
will  help  to  prevent  the  use  of  explosives  by  terrorists  and  other  criminals,  increase  the 
probability  of  detection  and  enhance  prevention  and  intervention  opportunities.  Some 
industrial  stakeholders  have  pointed  out  that  alternative  security  measures  may  achieve  the 
same effect. The benefits of the remote immobilisation proposal have also been questioned. 

Limit the spread of bomb-making experience over the internet (part of recommendation 41) 

Limiting the spread of bomb-making information and experience is very difficult. Given that 
websites where such information may be found are frequently visited and in light of the use of 
such information  by  terrorists,  it  would  be a  proactive and beneficial measure to reduce the 
use of IEDs. It would contribute to constraining the illicit manufacture of explosives, prevent 
their overall use and reduce their reliability and potency.  

5.4.1.3.  Detection Measures 

Create  a  database  containing  the  specifications  of  explosives  produced  within  the  EU 
(recommendation 32.) 

The collection of data on commercially produced explosives would have a positive impact as 
it would help with the fast identification of the products and their source. This would facilitate 
ongoing  investigations,  thus  increasing  the  probability  of  detection  of  terrorists  and  other 
criminals. There may however be issues of commercial confidentiality, as manufacturers may 
be reluctant to share all details of their products (perhaps just the necessary information for 
forensics and detection, but this could make the database less useful). 

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Create a European wide certification scheme for detection solutions (recommendation 26.) 

At  present,  some  certification  takes  place,  following  testing,  at  the  level  of  the  individual 
Member  States,  particularly  in  the  aviation  sector,  whilst  other  countries  do  not  have 
certification  procedures  in  place.  An  EU-wide  certification  scheme  would  enable  detection 
equipment companies to access the EU market as a whole as opposed to having to apply to 
each country. This would in principle be beneficial in terms of creating economies of scale, 
single  market  integration  and  resolving  delays  between  ordering  and  obtaining  well-
functioning  equipment.  It  would  be  important  to  learn  from  the  lessons  with  regard  to 
detection standards in aviation security. 

The  financial  costs  for  setting  up  a  scheme  in  terms  of  administrative  expenses,  human 
resources and expert inputs would be medium. However, given the scale of the industry and 
the  increasing  investments  in  detection,  there  would  be  economic  cost-efficiencies  for 
companies  in  the  longer  term  as  the  system  would  accept  a  product  for  all  EU27.  Reduced 
administrative  costs  could  accrue  in  the  longer  term  for  Member  States  as  each  would  no 
longer  need  to  go  through  a  certification  procedure.  There  is  a  possible  need  to  change  EU 
legislation. 

Create a European wide testing scheme for detection solutions (recommendation 27.) 

As under the action implementing recommendation 26, testing is at present mainly undertaken 
by  the  individual  Member  States,  while  other  countries  do  not  have  sufficient  resources  to 
launch  their  own  testing  schemes.  An  EU-wide  scheme  would  therefore  be  beneficial,  as 
Member States could share testing data and pool testing costs. This could offset development 
costs  and  help  stimulate  innovations  and  improvement,  thus  contributing  to  increased 
detection probability and increased prevention and intervention opportunities. In some sectors 
requiring  detection,  public  authorities  are  best  placed  to  undertake  testing  and  trialling,  as 
they have easier access to explosives.  

Create a European wide trialling scheme for detection solutions (recommendation 28.) 

The benefits of creating this scheme are similar to those described directly above. EU wide 
trialling would enable Member States to share information and data and would improve the 
overall  effectiveness  and  quality  of  detection.  However,  the  performance  of  detection 
equipment is difficult to trial and measure in all contexts (e.g. large-scale outdoor events). 

5.4.1.4.  Preparedness and response measures 

Create  the  possibility  for  relevant  law  enforcement  authorities  to  request  providers  to  shut 
down mobile phone antennas in the case of a threat of a terrorist attack (recommendation 44. 
and 46.) 

Mobile phones have been used as firing switches in two ways. The Madrid cell did not utilise 
the network, but the time alert system on the phone itself. Other groups across the world e.g. 
in Chechnya, South Africa, Iraq and Northern Ireland have sought to initiate IEDs by dialling 

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a  mobile  phone  that  in  turn  would  set  off  a  detonator.  Counter-measures  involving  phone 
networks are highly complex and technical. In order to function effectively, measures must be 
developed and put in place with the network providers as pre-planned contingency plans. It is 
important  for  national  authorities  to  first  liaise  with  their  network  providers  to  agree  on 
specific plans.  

5.4.2.  Overall assessment of Policy Option 3 

Two  of  the  14  actions  are  assessed  as  ‘3’  with  respect  to  their  contribution  to  the  general 
objective.  They  are:  the  establishment  of  a  system  concerning  the  regulation  of  explosive 
precursors; and, activities to limit the spread of bomb making experience over the internet. In 
combination  the  actions  contribute  to  all  of  the  specific  objectives  but  only  one  action 
contributes  to  specific  objective  5,  to  reduce  the  smuggling  of  explosives  into  the  EU  for 
illicit use by terrorists. 

The costs of most of the actions in this Policy Option are uncertain. In one case, the formal 
vetting  of  all  employees  involved  in  the  manufacture,  storage,  distribution  and  use  of 
explosives,  the  costs  are  both  uncertain  and  high  and  the  anticipated  contribution  to  the 
general objective is low.  

Seven of the additional actions may require changes to EU legislation. Four additional actions 
may  impact  on  fundamental  rights.  Environmental  effects  are  expected  as  a  result  of  2 
additional actions. 

The dependency on other actors to implement the additional actions in this Policy Option is 
higher than in Policy Option 2. 

Since  Policy  Option  3  includes  the  measures  set  out  in  Policy  Option  2,  it  should  be 
underlined that the impacts of the actions included in Policy Option 2 will remain unchanged. 
In  other  words,  the  14  additional  actions  included  in  this  option  will  not  influence  these 
impacts. 

5.5. 

Policy option 4 – Maximum option 

5.5.1.  Assessment by action 

There are seven ‘actions’ in this Policy Option that are additional to those in Policy Option 3. 
Each of these is briefly considered in turn. A more detailed assessment is provided in Annex 
1. 

5.5.1.1.  Prevention Measures 

Introduce a system for the recording of the identity of the buyer of precursors above certain 
quantities and/or concentrations (recommendation 7.) 

The overall awareness of staff in businesses selling precursors is critical and there have been a 
number  of  instances  in  different  countries  where  public  and  business  awareness  has  been 

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decisive  in  alerting  the  authorities  to  a  potential  conspiracy  to  cause  an  explosion  by  a 
terrorist  group.  The  introduction  of  a  system  to  record  the  identity  of  the  buyer  might 
therefore  not  only  assist  in  the  detection  of  purchases  after  an  incident,  but  also  to  make 
sellers  more  alert.  The  recording  could  also  act  as  a  deterrent.  The  action  would  therefore 
contribute to the prevention of the use of explosives by terrorists and criminals, increase the 
constraints  on  the  illicit  manufacture  of  explosives  and  reduce  the  liability  and  potency  of 
IEDs as terrorists and criminals may decide to use alternative (less strong) precursors which 
are not subject to recording. 

The  financial  and  economic  costs  of  developing  such  a  recording  system  may  be  high,  as 
every seller would have to invest some time in record-keeping. Whilst on an individual level 
this  is  minor,  the  number  of  sellers  is  very  large  across  the  EU.  There  are  some  potential 
fundamental rights issues as it could affect data protection principles – however processing of 
personal  data  would  always  have  to  take  place  in  accordance  with  existing  data  protection 
legislation. 

A  European  minimum  standard  and  industrial  guidance  by  way  of  an  appropriate  code 
concerning the security of storage of explosives precursors (recommendation 8.) 

Standards and codes in the storage of explosives precursors would indeed increase security, 
thus  contributing  to  the  prevention  of  the  use  of  explosives  by  terrorists  and  criminals, 
increasing  the  constraints  on  the  illicit  manufacture  of  explosives  and  reducing  the  liability 
and  potency  of  IEDs.  However,  the  feasibility  of  accomplishing  successful  implementation 
may be questionable as a broad range of end-users would have to abide by the standards. It is 
important to first define ‘storage’, which could potentially cover a huge area, from farmlands 
to shop storage spaces. It is worthwhile noting that small-scale actors are indeed a potential 
target  of  terrorists:  the  400  litres  of  peroxide  that  was  used  for  the  UK  21/7  2005  attacks 
constituted  half  of  what  was  available  in  the  shops  in  England.  It  was  all  bought  from  3-4 
retailers. 

The  financial  costs  for  implementing  and  enforcing  standards  or  a  code  would  have  to  be 
assessed separately, but it is estimated that they would be high. Authorities and industries in 
certain Member States might find it easier to introduce these than other Member States, with 
less suitable infrastructure and less financial resources. EU legislation could be needed should 
it  be  decided  to  make  the  standards  legally  binding  across  the  EU.  There  are  possibly 
environmental impacts from additional security measures for storage (e.g. fencing).  

Establish a system of reporting suspicious transactions (recommendation 5.) 

The  action  would  both  increase  the  overall  awareness  of  sellers  and  put  in  place  concrete 
measures  to  facilitate  reporting  with  a  specialised  authority.  Likewise,  authorities  and  law 
enforcement  bodies  would  be  kept  continuously  informed  of  the  purchase  potentially 
dangerous  precursors.  It  would  thus  have  a  positive  impact  on  preventing  the  use  of 
explosives by terrorists and criminals, increasing the constraints on the illicit manufacture of 
explosives  and  reducing  the  liability  and  potency  of  IEDs.  In  the  UK,  such  benefits  can  be 
illustrated by the case of Mohammed Sidique Khan and his fellow 7/7 (2005) bombers, who 

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purchased  a  significant  quantity  of  peroxide  and  acetone  precursors  for  the  construction  of 
their TATP rucksack bombs. 

It  is  important  to  establish  a  clear  definition  of  ‘suspicious  transactions’.  Several  existing 
industrial  and  national  definitions  can  be  used  as  an  example  (e.g.  the  guidelines  of  the 
Chemical Industries Association and the Know Your Customer campaign). The system could 
for  example  a)  follow  the  concept  used  to  detect  terrorist  financial  transactions  i.e.  all 
transactions  above  a  certain  quantity  /  concentration  have  to  be  reported,  then  analysed  and 
assessed.  Alternatively,  it  could  b)  be  ‘front-loaded’,  relying  upon  the  trader  to  make  the 
decision as to what is suspicious or not. More research would be needed to fully explore the 
viability  of  these  two  options.  The  system  should  not  be  strictly  based  on  transaction 
restrictions  but  also  on  the  purchase  of  combinations  of  substances  which  are  suspicious. 
Finally,  due  account  should  also  be  taken  of  precursors  that  can  be  used  to  create  low 
explosives.  It  will  be  important  to  combine  the  system  with  awareness-raising  (e.g.  actions 
implementing recommendations 1-3). 

The financial and economic costs of reporting systems could vary greatly. Some start-up costs 
would  be  involved  to  set  up  the  authority  to  which  producers  and  sellers  should  report  to, 
including equipment and training of staff. The costs would be high in the case of system a) 
mentioned  above.  The  obligation  to  report  on  every  transaction  going  beyond  a  certain 
threshold  would  put  a  high  strain  on  traders  (in  terms  of  human  resources  needed  for 
reporting)  and  would  entail  very  high  administrative  costs  to  analyse  and  assess  all 
transactions. The costs are low when the decision to report on a certain transaction is left to 
the trader as in b) above, as it will require less time of those that are selling the products. In 
addition,  the  administrative  costs  will  also  be  reasonable  as  the  number  of  transactions 
reported  is  likely  to  be  much  lower.  Depending  on  the  extent  and  use  of  the  information 
contained in the system it could affect fundamental rights related to data protection principles 
–  however  all  processing  of  personal  data  would  need  to  take  place  in  accordance  with 
existing data protection legislation. 

A  binding  system  concerning  the  notification  to  the  relevant  national  authority  of  any 
transactions  involving  the  products  on  the  list  which  can  be  considered  suspicious 
(recommendation 6.) 

The  benefits  and  possible  downfalls  of  the  notification  system  are  similar  to  the  reporting 
system. However, the establishment of a binding system could be less beneficial and even be 
counter-productive. It would have a more ‘negative’ connotation as it would imply that those 
not reporting could potentially be prosecuted. A system based on voluntary inputs is likely to 
create more ‘goodwill’ than one that is imposed on traders. 

As  mentioned  under  the  action  implementing  recommendation  5  above,  the  financial  and 
economic  costs  could  vary  greatly.  A  binding  system  would  however  automatically  entail 
relatively  higher  costs  for  enforcement  (e.g.  controls  whether  all  producers  and  traders  are 
reporting correctly, fining those that are not, etc). 

Introduce a complete ban on selling precursors to minors (recommendation 10.) 

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Whilst sensible and beneficial, the action may prove very difficult to enforce and may have a 
relatively low impact (the precursors will be purchased by adult terrorists instead). Equivalent 
great efforts to prevent the sale of fireworks, alcohol and cigarettes to juveniles and minors in 
most Member States testify to the challenges faced. 

The  financial  costs  of  the  introduction  of  the  ban  are  estimated  to  be  low.  There  could  be 
some  economic  effects  for  retailers  but  these  are  expected  to  be  minor.  There  are  possible 
environmental and safety benefits. 

Harmonise EU requirements for the licensing and handling of large amounts of pyrotechnic 
articles (recommendation 43.) 

Pyrotechnic  articles  have  been  used  in  the  past  to  develop  IEDs,  for  example  the  case  of 
David  Copeland  who  created  a  homemade  explosive  that  killed  six  persons  from  black 
powder obtained from fireworks. The market is deregulated in several Member States, such as 
the  UK  which  since  10  years  no  longer  requires  a  licence  for  producing  and  handling 
pyrotechnic articles. In addition, their size and potency is increasingly making them similar to 
explosive devices. The action could thus prevent the use of explosives by terrorists and other 
criminals,  increase  the  constraints  on  their  illicit  manufacture  and  reduce  the  reliability  and 
potency of explosive devices.  

The  financial  costs  would  be  high  for  administrations  and  enterprises,  relating  to  the 
development  or  further  elaboration  of  licensing  systems,  control,  enforcement  and 
compliance.  The  action  would  also  have  economic  effects  as  the  production  and  storage  of 
such  articles  could  become  more  expensive.  At  the  same  time  there  may  be  single  market 
benefits. Some environmental and safety benefits could accrue.  

5.5.1.2.  Detection measures 

Develop minimum detection standards (recommendation 25.) 

Minimum detection standards may help to increase the overall quality of detection systems, 
thus  increasing  the  probability  of  detection  as  well  as  prevention  and  intervention 
opportunities.  It  would  be  important  to  learn  from  the  experiences  in  the  field  of  aviation 
security, where a framework regulation (No 2320/2002), adopted in 2003, made the security 
measures set out by the European Civil Aviation Conference (ECAC) compulsory within the 
EU.  The  Annexes  to  the  Regulation  set  out  common  basic  standards  for  aviation  security, 
laying down performance criteria and acceptance tests for detection equipment. The standards 
also relate to what screening and other control processes should be used, which items should 
be checked and skills requirements for staff. Standards should be precise whilst still leaving 
flexibility to take account of different contexts. Alternative measures, such as the sharing of 
good practices and the use of product information sheets could be equally beneficial without 
setting minimum standards. 

The  development  of  minimum  detection  standards  could  be  undertaken  at  a  low  costs. 
However,  the  financial  costs  for  their  implementation  would  be  medium,  including 

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administrative costs, expert inputs and costs for companies. For legally binding standards EU 
legislation would have to be developed. 

5.5.2.  Overall assessment of Policy Option 4 

All of the seven actions added under Policy Option 4 would make a positive contribution to 
the general objective. Two of these actions are rated as ‘3’ with respect to their effectiveness 
with  regard  to  the  general  objective.  They  are:  the  establishment  of  a  system  of  reporting 
suspicious transactions; and, harmonising EU requirements for the licensing and handling of 
large amounts of pyrotechnic articles. However, in both cases the costs are likely to be both 
high and unpredictable. 

Five additional actions may require changes to EU legislation. Three additional actions may 
affect fundamental rights. For two additional actions, environmental effects are anticipated. 

Indeed  the  costs  of  all  bar  one  of  the  additional  ‘actions’  in  this  option  are  both  high  and 
uncertain. In three cases the impact on the general objective is assessed as ‘1’ hence relatively 
minor. 

Since Policy Option 4 includes the measures set out in Policy Options 2 and 3, it should be 
underlined  that  the  impacts  of  the  actions  included  in  Policy  Option  2  and  3  will  remain 
unchanged. In other words, the 7 additional actions included in this option will not influence 
these impacts. 

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5.6. 

Overall assessment 

Taken in combination the 45 actions in the Action Plan contribute to the specific objectives as 
follows: 

•  SO1  Prevent  the  use  of  legally  and  illicitly  manufactured  explosives:  (overall 

rating 51) 

•  SO6 Increase the chances of intervention (overall rating 45) 

•  SO4 Increase the probability of detection of terrorists illicitly handling and using 

explosives and precursors (overall rating 43) 

•  SO2  Increase  the  constraints  on  the  illicit  manufacturing  of  explosives  (overall 

rating 31) 

•  SO3 Reduce the reliability and potency of IED (overall rating 23) 

•  SO5 Reduce the smuggling of explosives into the EU for illicit use by terrorists 

(overall rating 4) 

With  the  exception  of  the  low  emphasis  on  activities  related  to  the  illicit  importing  of 
explosives there is a good balance in the contributions of the actions to the specific objectives.

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6. 

THE PREFERRED POLICY OPTION  

6.1. 

Challenges in identifying the preferred option 

The  identification  of  the  preferred  option  in  this  Impact  Assessment  poses  several  special 
challenges. In particular:  

•  The  Action  Plan:  The  subject  of  the  Impact  Assessment  is  an  Action  Plan 
containing 45 separate actions. Some of these are preliminary in nature. Others are 
yet  to  be  defined  precisely  and  each  is  intended  to  impact  on  the  underlying 
problem  in  different  ways.  Many  are  expressed  as  recommendations  rather  than 
actions.  The  links  between  particular  actions  and  the  achievement  of  objectives 
are  often  indirect.  Some  costs,  particularly  the  indirect  costs  to  economic  actors 
are potentially very high and difficult to predict. Some of the actions, particularly 
those that lead to subsequent legislation could themselves be the subject of future 
Impact Assessments.  

•  The nature of the problem: The number of terrorist incidents involving explosives 
within  the  EU  has  been  low.  There are  many,  but  an  unknown  number  of,  plots 
that  might  have  led  to  terrorists  using  explosives  that  did  not  occur.  The 
characteristics  of  the  threat  from  terrorism  have,  and  will  continue  to  change. 
There  is  concern  that  there  could  be  marked  increases  in  incidents  that,  by  the 
nature of the motivation for them and the means of execution, could be both more 
devastating  and  difficult  to  prevent  than  hitherto  (for  example,  suicide  bombers 
protesting  against  ‘western  society’).  This  concern  influences  the  public  policy 
priority afforded to security and preventive measures.  

•  The  role  of  the  EU:  The  primary  responsibility  for  security  rests  with  Member 
States. Indeed, many of the actions are dependent on the ‘voluntary’ cooperation 
of  Member  States  and  agencies  at  other  levels.  Bilateral  and  multilateral 
cooperation between Member States, not necessarily involving the EU is and will 
remain  important  in  achieving  the  general  objective.  Some  actions  and 
interventions are however best undertaken at the EU level. 

•  The  role  of  Impact  Assessment:  the  purpose  of  Impact  Assessment  is  to  inform 
public policy making and the choice between broad Policy Options. However, the 
Action Plan includes most of the plausible actions that could be taken at the EU 
level to address the problems identified. Very few of the actions are alternatives. 
The  Impact  Assessment  process  can  only  to  a  limited  extent  ‘second  guess’  the 
usefulness of individual actions within the Action Plan. These actions have been 
the  subject  of  detailed  discussion  by  security  experts  and  stakeholders  from  the 
explosives, chemicals and detection industry. Also, account needs to be taken of 
the interrelationships between the individual actions and their sequencing. One of 
the advantages of an Action Plan is that it should enable a coordinated approach 
and maximise the potential for synergies between actions.  

However,  it  is  evident  from  the  assessment  of  Policy  Options  undertaken  in  section  5  and 
supported by the assessment of the individual actions in Annex 1 that some actions are likely 
to be more cost effective than others.  

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6.2. 

The preferred option 

Given  the  difficulties  outlined  in  section  6.1  above,  this  impact  assessment  report 
recommends that all of the actions proposed by the ESETF should be included in the Action 
Plan  –  without  however  committing  the  Commission  already  at  this  stage  to  full 
implementation of all actions. This can be further explained as follows. 

All  of  the  actions  in  Policy  Option  2  should  be  included  in  the  preferred  Policy  Option.  Of 
those  additional  actions  included  in  Policy  Option  3  all  should  be  included  in  the  preferred 
Policy  Option  with  the  following  reservations.  Further  feasibility  studies  are  required  to 
identify  the  parameters  of:  a  system  concerning  the  regulation  of  explosives  precursors; 
procedures for formal licensing and vetting of those handling explosives; and, the accounting 
of raw materials used in the manufacture of explosives. 

In  general  terms  Policy  Option  4  is  the  preferred  option  with  the  stipulation  however  that 
further feasibility studies and consultations need to be taken forward concerning some of the 
actions identified in Option 4. There are a number of actions within Policy Option 4 that have 
high and uncertain costs and have been assessed as being only ‘moderately’ effective. These 
actions may have merit but before they are pursued further feasibility and assessment work is 
needed. Of those actions included in Policy Option 4 only the introduction of a complete ban 
on selling precursors to minors should be immediately pursued,  subject to an assessment of 
the feasibility of enforcing such a ban. The remaining actions should be subject to feasibility 
work.  

The  analysis  of  impacts  has  also  shown  that  certain  measures  would  require  further 
development  in  order  to  work  out  the  details  of  the  proposed  measures  and  their  specific 
impacts. It is therefore suggested that the Action Plan should clarify that on the points where 
further feasibility work still needs to be carried out, the Commission is only committing itself 
to  pursuing  such  feasibility  work,  not  necessarily  to  any  subsequent  implementation.  Any 
possible implementation would necessarily be dependant on the results of the feasibility work. 
Table 6.1. below provides more detail on which of the measures identified should be subject 
to more feasibility work. 

An  analysis  of  the  impacts  of  the  particular  measures  identified  by  the  Explosives  Security 
Experts Task Force has shown that no single measure from among those set out in the Task 
Force  report  would  be  sufficient  by  itself  to  achieve  the  general  objective  of  reducing  the 
number  and  potency  of  terrorist  and  other  criminal  incidents  in  the  EU  using  explosives. 
When  combined  however,  these  measures  would  address  in  a  comprehensive  fashion  the 
security of explosives in the European Union and would significantly contribute to achieving 
all of the policy objectives identified above under Section 3. It should be noted here as well 
that there have been no indications that some of the measures proposed could interfere with 
each  other  in  a  negative  way  –  rather  it  is  the  cumulative  effects  of  the  actions  which  is 
expected to increase the overall effectiveness of the measures taken together. 

The work of the Explosives Security Experts Task Force, the Explosives Security conferences 
organised by the Commission and more broadly the entire process of public-private dialogue 
concerning the security of explosives have contributed to the elaboration of a comprehensive 
set of measures concerning the security of explosives. None of the measures identified in the 
Explosives  Security  Experts  Task  Force  report  should  be  disregarded  as  they  are  an 
emanation  of  the  expectations  of  civil  society  and  relevant  public  authorities  in  the  EU. 
Consequently,  these  measures  should  be  included  in  the  Action  Plan  in  full,  although  as 

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indicated above, further feasibility work should be taken up concerning certain actions. This 
should be clearly indicated in the Action Plan. 

Table 6.1 – Summary and contents of preferred policy option 

Objectives 

Options and actions 

OPTION 2 - MINIMUM OPTION 

Horizontal measures 

Included in preferred 
option? Comments 

Improve the exchange of timely information and best practice 

39. and 40. Establish an Early Warning System 

50. Regularly organise an event on the security of explosives 

Develop threat assessments 

No ESETF recommendation number: Consider developing specialised threat 
assessments 

Strengthen explosives related research  

49. Improve the aggregation and spread of research results  

47. Perform further research on: 
1 - IEDs 
2 - Chemicals found at an investigation scene 
3 - Detection of explosives and precursors 
4 - Mobile explosives kits 

31. Perform further research concerning the detection of Improvised Explosive 
Devices at airports, in particular for hold luggage 

yes 

yes 

yes 

yes 

yes 

yes 

48. Perform further research to find inhibitors which could be added to precursors  

yes 

45. Support further research to find technical solutions to jam mobile phones 

yes 

Prevention measures 

Improve staff awareness and alerting concerning precursors 

1. Public authorities to provide security information to the entire precursor supply 
chain 

2. Simple means within supply chain to alert national authority  

3. Campaigns to raise staff-awareness all along supply chain 

Improve the control over transactions involving precursors 

yes 

yes 

yes 

9. Assessing benefits of creating a scheme for each precursor handled by retail 
sector, under which all packaging would be labelled with a code specifying subject of 
registration 

Feasibility work should 
consider alternative 
means to achieve 
objective 

Improve the control over explosives available on the market and pyrotechnic 

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articles 

19. Launch debate on the need to review the classification of "desensitized" 
explosives 

yes 

Improve the security of explosive facilities 

12. and 14. Effective Security Plans/Security Management Systems at all facilities 

yes 

Detection Measures 

Establish scenario based approach to identifying work priorities 

23. Setup of a working group to develop scenarios and to identify technology 
requirements 

24. Create matrix of what is desired and currently possible in each scenario 

Yes 

yes 

Developing minimum detection standards 

Part of 25 and 27: Develop mechanisms for the identification and dissemination of 
good practice in detection systems and use of detection equipment 

Should be considered as 
possible alternative to 
minimum standards 

Improving the exchange of information 

42. Ensure that security staff are provided with up-to-date information on new 
terrorist modi operandi 

yes 

30. Assess and improve where necessary the situation as regards the availability of 
training data and other information/feedback for manufacturers of detection solutions 

yes 

33. Create an end-user focused handbook concerning detection 

34. Create a network of experts on the detection of explosives 

Establish EU-wide certification, testing and trialling schemes 

29. Assess the need for the development of standards concerning certification, 
testing and trialling processes. 

Improve the usage of detection technologies in specific locations 

Feasibility work should 
consider alternative 
means to achieve 
dissemination objective 

yes 

yes 

31. Improve the use of detection technologies at airports, railway stations and other 
public facilities. 

yes 

Preparedness and response measures 

Improve the exchange of information and best-practices among relevant 
Member State authorities 

38. Establish a European EOD Network 

yes 

OPTION 3 - INTERMEDIATE OPTION 

Horizontal Measures 

EN 

60 

   EN 

 
  
  
  
  
  
  
  
  
  
  
  
Improve the exchange of timely information and best practices 

35, 36 and 37. Create a European Bomb Database 

yes 

Prevention Measures 

Improve the regulation of explosives precursors available on the market 

4. The establishment of a system concerning the regulation of explosives precursors 
available on the market 

Improve the control over explosives available on the market and pyrotechnic 
articles 

yes, but impact and 
costs dependent upon 
the actual system. 
Feasibility work required 

21. Ensure that each Member States has formal systems for authorising, regulating 
and licensing the manufacture, storage, sale, use and possession of explosives 
including by private persons.  

yes, but feasibility work 
required 

Improve the security of explosives facilities 

13. Introduce an obligation for the relevant national authorities to keep explosives 
manufacturers and distributors informed as to the regional threat at all times 

yes 

20. Raw materials used in the manufacture of bulk explosives and finished product 
should be periodically accounted for and reconciled as approved by the National 
Authorities. 

yes, but feasibility work 
required 

15., 16., 17. Improve the security of Mobile Explosive Manufacturing Units (MEMUs) 

yes 

Improve the security vetting of personnel 

11. All personnel employed in the manufacturing, storage, distribution and use of 
explosives should be vetted and hold a formal authorisation to have access to 
explosives. 

yes, but feasibility work 
required 

Improve the security of transport of explosives 

18. All EX/II and EX/III vehicles carrying explosives should be equipped with certain 
security enhancement solutions 
These security solutions include: 
1) be fitted with 24 hour 
2) be capable of immobilising the engine remotely if safe and applicable  

yes 

Reduce the supply and quality of information on how to illicitly manufacture 
explosives 

Part of 41: Limit the spread of bomb-making experience over the internet 

yes 

Detection Measures 

Improving the exchange of information 

32. Create a database containing the specifications of explosives produced within 
the EU 

yes 

Establish EU-wide certification, testing and trialling schemes 

EN 

61 

   EN 

 
  
  
  
  
  
  
  
  
  
  
  
26. Create a European wide certification scheme for detection solutions 

27. Create a European wide testing scheme for detection solutions 

28. Create a European wide trialling scheme for detection solutions 

Preparedness and response measures 

depends in part on 
results of 
recommendation 29 to 
assess need for 
standards  

depends in part on 
results of 
recommendation 29 to 
assess need for 
standards  

depends in part on 
results of 
recommendation 29 to 
assess need for 
development of 
standards 

Develop specific preparedness and response measures for terrorist threats 
using explosives 

44. and 46. Create the possibility for relevant law enforcement authorities to request 
providers to shut down mobile phone antennas in the case of a threat of a terrorist 
attack 

yes 

OPTION 4 - MAXIMUM OPTION 

Prevention Measures 

Improve the regulation of explosives precursors available on the market 

7. Introduce a system for the recording of the identity of the buyer of precursors 
above certain quantities and/or concentrations. 

Feasibility work should 
be undertaken 

8. A European minimum standard and industrial guidance by way of an appropriate 
code concerning the security of storage of explosives precursors  

Improve the control over transactions involving precursors 

5. Establish a system of reporting suspicious transactions.  

Feasibility work should 
be undertaken, likely to 
require Impact 
assessment 

Feasibility work should 
be undertaken 

6. A binding system concerning the notification to the relevant national authority of 
any transactions involving the products on the list which can be considered 
suspicious 

Feasibility work should 
be undertaken 

10. Introduce a complete ban on selling precursors to minors. 

Improve the control over explosives available on the market and pyrotechnic 
articles 

yes, but feasibility work 
required to assess 
likelihood of enforcement 

EN 

62 

   EN 

 
  
  
  
  
  
  
  
  
  
43. Harmonise EU requirements for the licensing and handling of large amounts of 
pyrotechnic articles 

Detection measures 

Developing minimum detection standards 

25. Develop minimum detection standards 

Feasibility work should 
be undertaken, likely to 
require Impact 
assessment 

Feasibility work should 
consider alternative 
means of improving 
quality of detection 
equipment. 

EN 

63 

   EN 

 
  
  
7. 

MONITORING AND EVALUATION 

Monitoring  the  implementation  of  the  Action  Plan  will  be  critical  to  the  success  of  the 
initiative.  

The monitoring and evaluation of the Action Plan will in one respect be straightforward. The 
general  objective  is  clear  and  it  is  easy  to  measure  whether  or  not  it  has  been  achieved. 
However, if the number of incidents involving terrorism and their potency declined this would 
not necessarily be attributable to the Action Plan. In the same light, should the numbers and 
severity of incidents radically increase, this would not necessarily signal that the Action Plan 
was  not  successful  either.  The  Action  Plan  is  not  designed  to  address  the  root  causes  of 
terrorism, rather it is constructed to reduce and ideally prevent the harm that arises from acts 
of  terrorism.  Indeed  the  rationale  for  the  Action  Plan  is  greatest  should  the  drivers  of  and 
motivations for terrorism strengthen. 

In  other  respects  there  are  important  challenges  in  creating  and  applying  a  monitoring  and 
evaluation regime. In particular: 

•  At the level of general and specific objectives a number of useful indicators can 
be defined that would provide a basis for monitoring. These are indicated in Table 
7.1.  However,  there  are  no  published  statistics  pertinent  to  these  indicators  and 
care  and  effort  is  required  in  order  to  assemble  information  to  inform  these 
indicators. Some of the most useful information is not in the public domain. The 
problem assessment section of this report illustrates some of the information and 
sources available. 

•  The  Action  Plan  contains  45  actions.  Some  of  these  themselves  would  require 
very  careful  monitoring  and  evaluation.  This  is  particularly  the  case  for  the 
actions that may generate significant economic costs and those actions where the 
links  between  the  intervention  and  the  achievement  of  the  general  and  specific 
objectives are complex and indirect. Examples of the former type of actions where 
the  costs  are  assessed  as  high  and  uncertain  include  (14)  vetting  all  personnel 
(including users) involved in explosive and (7) systems for identifying the buyers 
of all precursors (above thresholds to be defined). Examples of the latter type of 
action where the links are complex include the actions that are designed to foster 
improvements  in  detection  equipment  and  systems  that  may  involve  significant 
public financial support (yet to be determined). 

Table 7.1 Objectives, potential indicators and sources of information 

Objectives 

Potential indicators  

Sources and methods 

General Objective: To 
reduce the number and 

The numbers of incidents of terrorism 
using explosives 

Europol, EOD units, Press reports 

EN 

64 

   EN 

 
Objectives 

Potential indicators  

Sources and methods 

potency of terrorist 
incidents in the EU 
using explosives. 

The lives lost, injuries and costs of 
damage to property of terrorist 
incidents using explosives. 

Estimates from official and other 
sources. 

Specific objective: To 
prevent the use of 
legitimately and illicitly 
manufactured 
explosives by terrorists; 

To increase the 
constraints on the illicit 
manufacture of 
explosives by criminals 
and terrorists 

To reduce the reliability 
and potency of ‘home 
made’ explosives or 
components 
manufactured by 
criminals and terrorists 

To increase the 
probability of detection 
of terrorists illicitly 
handling and using 
explosives and 
precursors 

To reduce the 
smuggling of explosives 
into the EU destined for 
illicit use by terrorists 

To increase the chances 
of prevention and 
intervention 
opportunities by law 

The indirect effects of terrorism on 
delays, disruption and loss of liberties. 

Estimates from official and other 
sources. 

Numbers of plots thwarted. 

Rough estimates can be constructed from 
records of trials 

Number of unsuccessful terrorist 
incidents (for example, explosions not 
occurring as planned). 

Europol, EOD units, Press reports, 
records of trials 

Instances of thefts of explosives 

Europol, EOD units, Press reports, 
however, reliable data is not likely to be 
available in the public domain 

Numbers of plots, and unsuccessful and 
successful incidents using illicitly 
manufactured explosives.  

Such an indicator would be of particular 
value if it distinguished between 
different types of explosives.  

Instances of terrorists possessing of 
precursors 

Some information available from press 
and trial reports. Other information not in 
the public domain 

Number of unsuccessful terrorist 
incidents (for example, explosions not 
occurring as planned) 

Europol, EOD units, Press reports, 
records of trials 

The lives lost, injuries and costs of 
damage to property of terrorist 
incidents using explosives. 

Estimates from official and other 
sources. 

Detections of explosives and precursors 

Press reports, records of trials. Estimates 
from official and other sources. 

Detections leading to prosecutions 

Records of trials 

Seizures of explosives at EU borders. 

Press reports, police records. 

Detections of illicit explosives at 
borders 

Press reports, police and border control 
records 

Detections of explosives and precursors  Reliable data may be difficult to obtain. 

Reports received of suspicious 
transactions 

Evidence has to be interpreted with 
caution. The public’s level of suspicious 

EN 

65 

   EN 

 
 
Objectives 

Potential indicators  

Sources and methods 

enforcement bodies 

Plots thwarted by law enforcement 
bodies 

is likely to vary as will the numbers of 
false alerts.  

Reliable data difficult to obtain. Trial 
records, pending prosecutions and 
information on the grounds for suspects 
being detained provide relevant 
information. 

Given the importance of the topic and the EU Action Plan, which will need to be discussed 
within Council as well, regular monitoring of the state of implementation of the action plan 
should  be  foreseen,  as  well  as  an  evaluation  mechanism.  Both  of  these  measures  must  be 
proportionate and take account of the fact that an evaluation of all actions proposed will not 
be effective. A scoreboard-like system for monitoring the implementation of the action plan 
would probably be the best solution. In those cases where legislative measures are proposed 
these  should  also  contain  their  own  evaluation  systems  in  line  with  general  Commission 
policy on this point. 

In  order  for  this  to  work,  each  Member  State  should,  on  an  annual  basis,  provide  to  the 
Commission information concerning progress in the implementation of this action plan. Based 
on the Member State reports, the Commission will regularly assess the progress made in the 
implementation of the Action Plan, with a view to identifying what further measures need to 
be taken and selecting new priorities. 

As a final procedural point it should be mentioned here that this Impact Assessment report is 
not  intended  to  serve  as  an  ex-ante  evaluation  as  required  under  the  financial  procedures 
established by the Commission. 

EN 

66 

   EN 

 
ANNEX 1 – DETAILED ASSESSMENT OF POLICY OPTIONS 

Policy option 1 – Status quo 

Measure / action 

Rec. 
no 

Competent 
body 

Assessment of benefits 

Financial and economic effects 

G
O 

S1 

S2  S3  S4  S5  S6  Effects 

on 

fundamental 
rights 

Environment
al effects 

Horizontal Measures 

1: 

Objective 
the 
exchange  of  timely  information 
and best practices 

Improve 

Europol / Eurojust 

2 

2 

2 

No new issues  No 

new 

issues 

Objective 
explosives related research 

3: 

Strengthen 

Current  FP7 
research  with 
regard  to  detection  and  public 
security  (e.g.  Security  Research 
Call 1 of Dec 2006) 

Prevention measures 

Objective  4:  Improve  the  control 
over  explosives available  on  the 
market and pyrotechnic articles 

the 

Ensure 
identification  and 
tracing  of  explosives  based  on 
the 
in 
the  system  proposed 
Commission  Directive  on 
the 
identification  and  traceability  of 
explosives 
use 
for 
(Traceability Directive). 

civil 

2 

No new issues  No 

new 

issues 

2 

2 

2 

No new issues  No 

new 

issues 

22 

Commission 
/MS 

of 

implementation 

The 
the 
Traceability  Directive  would  have  a 
medium  impact  on  the  objective  of 
decreasing  the  number  and  potency 
of 
terrorist  and  other  criminal 
incidents in the EU using explosives. 
It  would  specifically  contribute  to 
preventing  the  use  of  legitimately 
and  illicitly  manufactured  explosives 
by  terrorists  and  other  criminals.  It 

requires 

adapting 

The  measure  would  entail  a 
medium cost for manufacturers, as 
current 
it 
packaging  methods  to  include  the 
new 
information.  Costs  may 
further  increase  if  the  traceability 
requirements  are  not  the  same  as 
those requested by third countries. 
to  be 
Such  costs  are 

likely 

EN 

67 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competent 
body 

Assessment of benefits 

Financial and economic effects 

would  also  increase  the  chances  of 
intervention 
prevention 
and 
law  enforcement 
opportunities  by 
bodies. 

charged on the clients. 

The  explosives  covered  by 
the 
Traceability  Directive  are  ready  to 
use  commercial  explosives.  The 
information  gathered  by  way  of  the 
draft Directive will be incorporated in 
the electronic data system set up by 
certain  EU  Member  States  and  is 
exchange 
intended 
to 
information  about 
prevent malicious use. 

thefts  and 

help 

to 

that 

indicated 

Industrial  actors 
it 
would  be  important  to  ‘streamline’ 
the  coding  with  developments  in 
third  countries  and 
if  possible 
introduce  a  globally  used  tracing 
method.  Increasingly  third  countries 
(e.g.  USA  and  Brazil)  are  also 
putting 
traceability 
place 
requirements. 

in 

harmonisation 

Council  Directive  93/15/EEC  on 
the 
the 
provisions relating to the placing 
on the market and supervision of 
explosives for civil uses 

of 

G
O 

1 

S1 

S2  S3  S4  S5  S6  Effects 

on 

fundamental 
rights 

Environment
al effects 

No new issues  No 

new 

issues 

Objective 7: Improve the security 
of transport of explosives 

legislation  and  working 

ADR 
group on transport 

Objective  8:  Reduce  the  supply 
and  quality  of  information  on 
illicitly  manufacture 
how 

to 

1 

1 

No new issues  No 

new 

issues 

EN 

68 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
G
O 

1 

S1 

S2  S3  S4  S5  S6  Effects 

on 

fundamental 
rights 

Environment
al effects 

1 

1 

No new issues  No 

new 

issues 

Measure / action 

Rec. 
no 

Competent 
body 

Assessment of benefits 

Financial and economic effects 

cost, 

involving 
adoption, 

the 
Low 
and 
negotiation, 
implementation 
legislation. 
Higher  costs  will  be  incurred  for 
enforcement and sentencing. 

of 

explosives 

Harmonize criminal sanctions for 
distributing 
bomb-making 
experience over the Internet 

Part  of 
41 

MS/ 
Commission 

for 

The recent trial of the three persons 
in  the  UK  that  distributed  material 
from  Al-Qaeda,  constituted  the  first 
case  in  history  that  people  were 
convicted 
the  distribution  of 
terrorist  information.  Harmonisation 
of  criminal  sanctions  will  make  the 
EU  a 
to 
distribute  such  information  from,  but 
is 
the 
to 
unlikely 
phenomenon. 

less  attractive  place 

reduce 

proposed 

The  measure 
only 
addressed  the  persons  that  ensure 
the  distribution  (i.e.  placing  it  on  a 
server  and  making  sure  it  continues 
to work). It does not affect those that 
put  the  information  together,  nor 
does 
from 
downloading it. Distribution is indeed 
probably  the  only  activity  which  can 
realistically be identified. 

inhibit 

users 

it 

Detection Measures 

EU  legislation  in  the  area  of 
aviation security 

3 

2 

2 

2 

No new issues  No 

new 

issues 

EN 

69 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Policy option 2 – Minimum option 

Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

S
4 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

Horizontal Measures 

1: 

Objective 
the 
exchange  of  timely  information 
and best practices 

Improve 

Establish  an  Early  Warning 
System concerning explosives 

39 

Commissi
on/ MS/ 

Such a system would be used in 
order  to  exchange  information 
concerning: 

Europol 

Immediate threats; 

Theft of explosives (any kind); 

Theft of detonators; 

Theft  of  precursors; 
discussed) 

(to  be 

40 

Suspicious transactions; 

Discovery of new modi operandi 

The  system  should  be  available 
in  particular  to  Member  States 
authorities 
public 
(national 
points), 
contact 
Europol and all operational EOD 
units. 

security 

EN 

Similar  systems  exist  but  they 
do  not  cover  the  whole  EU 
(e.g.  G6)  and  are  mainly  used 
at  national  level.  The  creation 
of  an  EU-wide  system  would 
therefore 
beneficial, 
be 
provided  it  is  based  on  good 
practice and lessons learned in 
other  systems.  Inevitably,  with 
information, 
such 
some ‘practitioners’ in the field 
of counter-terrorism may rather 
relay 
information 
informally  and  bi-laterally  to  a 
foreign  colleague  they  trust, 
rather 
in  a 
than  placing 
central information system, 

sensitive 

such 

it 

There  are  many  examples  of 
the  benefits  of  EWS.  For 
example,  it  would  have  been 
extremely  useful  if  all  Member 
States  had  been 
instantly 
informed  of  the  theft  of  8.5 
tonnes  of  explosives  from  a 
quarry  in  Plevin,  France  in 
their  police 
1999, 
forces  and  other 
relevant 
actors. 

to  alert 

is 
It 
information 

important 
is 

that 

the 
handled 

3 

2 

2 

3 

No 

No 

No 

Low  to  medium  costs,  some 
efficiencies  if  linked  to  other 
systems  (e.g.  the  European 
Bomb  Database).  Costs 
would  include  setting  up  the 
organising 
system, 
information 
exchanges  of 
(virtual 
face-to-face). 
Ongoing  information  inputs 
from 
would  be 
Member States. 

required 

or 

The additional costs, bearing 
in  mind  that  most  inputs  are 
in  place  and  ensured  by 
Member  States  (e.g.  EOD 
units) are estimated at: 

Set-up  and  organisation: 
250,000 euro 

Internal  staffing:  2  FTE, 
totalling  100,000  euro  per 
year 

Inputs:  average  25  days  per 
Member State per year at an 
average  fee  of  400  euro, 
totalling  270,000  euro  per 
year 

70 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

S
4 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

(every 

two  years) 
Regularly 
organise  an  event  on 
the 
security  of  explosives  covering 
all relevant issues.  

50 

Commissi
on 

an 

Such 
event/conference 
should  involving  officials  from 
both 
the  public  and  private 
sectors where relevant. 

Objective  2:  Develop 
assessments 

threat 

Consider developing specialised 
threat 
on 
explosives 

assessments 

NEW  MS/Europ

ol/ Council 

appropriately  and  the  amount 
of 
sensitive 
information kept at a minimum. 

classified 

Such  a  regular  meeting  by 
experts  in  this  field  would  be 
beneficial  and  would  lead  to 
both  greater  knowledge  of 
developments  and  networking. 
The  meetings  would  need  to 
other,  more 
involve 
focused  networks 
that  are 
active  (e.g.  detection  experts, 
EOD units) 

the 

The meetings will also serve to 
monitor  the  action  plan  and  to 
increase public awareness. 

Not  possible  to  define  at  this 
stage  which  objectives  will  be 
most  affected  – 
this  will 
depend  on  the  focus  of  the 
events. 

Difficult  to  estimate  the  impact 
without  additional  clarifications 
as to  what these assessments 
will  cover.  In  addition,  most  of 
it  could  be  covered  by  the 
EWS.  Would  it  perhaps  be 

Outputs: 
reporting, 
(e.g. 
dissemination,  analysis)  4 
reports  of  20,000  euro, 
totalling 80,000 euro. 

Total:  700,000  euro  for  the 
first  year,  450,000  for  the 
following years. 

related 

to 
Low 
cost, 
organisation 
and 
coordination,  logistics,  travel 
and  subsistence  and  some 
expert fees. 

work: 

Preparatory 
background 
briefing 
programme 
invitation 
process, 
50,000 euro per event 

(e.g. 
document, 
speakers, 
outlines, 
etc): 

of 

2 

1 

1 

1 

1 

1 

1 

No 

No 

Possibly, 
some 
environmenta
l costs (flights 
and 
other 
transport) like 
any 
other 
event  of  this 
type. 

(e.g. 

travel, 
Logistics: 
subsistence, 
conference 
rooms):  approximately  1,000 
euro per person. 

Total:  Based  on  an  event  of 
200  persons,  250,000  euro 
per event. 

Not possible to assess costs. 

1 

1 

No 

No 

No 

EN 

71 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

S
4 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

more  correct  to  rephrase  the 
action  as  follows:  Specialised 
assessment  on  the  threat  of 
explosives? 

Objective 
explosives related research 

3: 

Strengthen 

Improve 
the  aggregation  and 
spread  of  research  results  both 
at EU level as well as at national 
level  across  the  EU  Member 
States 

49 

MS/ 
Commissi
on 

Depending  on  the  quality  and 
outcomes  of  the  research,  the 
action  would  help  to  increase 
the  overall  knowledge  in  the 
field of explosives security and 
avoid  overlaps  and  duplication 
of research efforts. 

Higher scoring possible but not 
at this stage 

Low 
cost, 
dissemination 
coordination. 

related 

to 
and 

and 
Coordination 
dissemination: 
(including 
identification of research and 
compilation of contact lists of 
people  whom  should  receive 
the 
information):  0,5  FTE 
totalling 25,000 euro. 

1 

1 

1 

1 

1 

1 

1 

No 

No 

No 

the 

long 

In 
term,  some 
positive  economic  benefits 
could occur as new research 
would  be  more  targeted  and 
all  Member  States  could 
benefit from results. 

2 

2 

2 

1 

2 

1 

1 

No 

No 

further 

Perform 
research  on 
improvised  explosive  devices 
and their properties 

47 

MS/ 
Commissi
on 

further 

Perform 
research  on 
dealing  with  big  amounts  of 
found  at  a  scene 
chemicals 
under investigation. 

research  would  assist 

Such 
EOD experts 

Perform  further  research  on  the 

Additional research to enhance 
the  security  of  explosives  will 
have a positive impact as it will 
help  to  find  practical  solutions 
to reduce the use of explosives 
by  terrorists.  The  benefits  are 
however  highly  dependent  on 
the  specifics  of  the  research. 
Specific  comments  on 
the 
research areas proposed are: 

1.  IEDs:  earlier  there  was  no 
literature  /  research  on  this 
type  of  manufacturing  of 

1.  Location-wise  it  may  be 
costly as these tests have to 
be  undertaken 
isolated 
environments. 

in 

2.  Location-wise  it  may  be 
costly as these tests have to 
be  undertaken 
isolated 
environments. 

in 

3.  High  cost,  especially  with 
detection 
to 
regard 
It  could  be 
technologies. 

EN 

72 

Yes, 
environmenta
l costs due to 
the  use  of 
chemicals, 
explosives 
and  the  need 
to  develop  or 
adapt 
laboratories. 

However, 
such  effects 
will be limited 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

S
4 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

detection  of  explosives  and 
precursors including through the 
use of additives.  

Enhancing both detectability and 
traceability 
be 
considered. 

should 

explosives  as 
it  had  never 
occurred.  It  is  therefore  very 
increase 
to 
important 
knowledge.  However, 
there 
are so many ways to create an 
IED 
is 
necessary. 

that  a  clear 

focus 

partly industry driven. 

research 

to 
4.  Further 
improve the kits would not be 
very  expensive.  It  can  be 
industry driven. 

Perform 
mobile explosives testing kits. 

research  on 

further 

Perform  further  research  to  find 
inhibitors  which  could  be  added 
to  precursors  to  explosives  to 
to 
prevent 
manufacture explosive devices 

them  being  used 

48 

MS/ 
Commissi
on 

for 

the 
themes  and 

The  exact  costs  for  research 
depend  on  the  allocations 
different 
made 
research 
the 
projects  selected.  A  total  of 
1,400  million 
is 
available through the FP7 for 
security research overall. 

euro 

2.  The  7/7  (London)  attacks 
showed  that  it  took  more  than 
two weeks to make the sites to 
be  investigated  safe  to  enter. 
The  action  should  rather  say 
scenes  containing  unstable 
rather  than  big  amounts  of 
chemicals.  The  MET  has 
training 
developed 
programme  which 
teaches 
police  officers  to  be  aware  of 
such materials.  

a 

3. Mobile kit may already exist. 
It  will  be  important  to  base 
research 
existing 
on 
experience. 

industry 

Potentially  a  positive  impact. 
Ongoing  and  past  research 
exists  and  should  be  built 
upon.  Various  actors  from  the 
chemical 
have 
however  indicated  that  it  is 
very 
identify 
inhibitors  which  do  not  affect 
the 
the 
product, especially in the case 
of  precursors  produced 
for 
industrial use. 

performance 

difficult 

to 

of 

Research  is  not  extremely 
expensive 
single 
precursors, but the variety of 
that  should  be 
chemicals 
addressed is huge. 

on 

2 

2 

2 

No 

No 

for 

The  exact  costs  for  research 
depend  on  the  allocations 
different 
made 
research 
the 
projects  selected.  A  total  of 
1,400  million 
is 
available through the FP7. 

the 
themes  and 

euro 

EN 

In 

addition, 

the 

actual 

73 

given the fact 
that 
such 
research 
must 
take 
place  within 
well 
controlled 
environments
. 

Yes, 
environmenta
l costs due to 
the  use  of 
chemicals 

EN 

 
  
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

S
4 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

further 
research 
Perform 
concerning 
the  detection  of 
Improvised Explosive Devices at 
airports,  in  particular  for  hold 
luggage 

31 

MS/ 
Commissi
on 

Support further research in order 
to  find  technical  solutions  for 
Member State authorities to jam 
mobile  phone  signals  in  critical 
areas 

45 

MS/ 
Commissi
on 

Research to better detect IEDs 
will have a positive effect. Little 
research  has  been  done  so 
far.  It  is  a  very  challenging 
the 
area 
identification  of  an  extremely 
high number of substances.  

implies 

as 

it 

Research to better understand 
the  effects  of  jamming  mobile 
phone  signals  and  to  identify 
‘secure’ ways of doing this will 
have  a  positive  effect.  It  will 
also  help 
the 
shutting  down  networks  (see 
also  actions  44  and  46  for 
more information) 

research 

to 

Too vague to rate. 

Prevention Measures 

Objective  1: 
awareness 
concerning precursors 

Improve 
and 

staff 
alerting 

implementation  /  insertion  of 
inhibitors  to  precursors  may 
be immensely expensive. 

to  high  costs 

Medium 
to 
finance research in this area, 
as it concerns a huge variety 
of chemicals. 

2 

2 

2 

No 

No 

No 

for 

The  exact  costs  for  research 
depend  on  the  allocations 
different 
made 
research 
the 
projects  selected.  A  total  of 
1,400  million 
is 
available through the FP7. 

the 
themes  and 

euro 

2 

No 

the 
of 
and 
life 

Possibly, 
respect 
private 
family 
which 
includes 
communi-
cations. 

Possibly, 
telephone 
masts 
transmitting 
certain 
ultrasounds 
to 
signals. 

jam 

to  medium  cost 

Low 
to 
this 
research 
finance 
rather  complicated  area  and 
to 
suitable 
solutions. 

elaborate 

in 

for 

The  exact  costs  for  research 
depend  on  the  allocations 
different 
made 
research 
the 
projects  selected.  A  total  of 
is 
1,400  million 
available through the FP7. 

the 
themes  and 

euro 

Public  authorities 
to  provide 
security information to the entire 
from 
precursor  supply  chain, 

1 

MS 

Awareness-raising is important 
to  help 
and  has  proved 
prevent  terrorist  attacks.  The 

The costs for the provision of 
such information are likely to 
be  high,  as  it  needs  to  be 

2 

2 

2 

2 

2 

No 

No 

EN 

74 

Possibly, 
some 
environmenta

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

l  costs 
for 
printing  and 
distribution. 

Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

S
4 

S
5 

S
6 

(police, 

responders 

manufacturers  to  the  retailers, 
first 
fire-
departments, bomb-squads) and 
educational  establishments 
to 
focus  attention  on  products  of 
concern. 

is 

and 

public 

information 

concept 
‘security 
of 
information’  is  to  be  clarified. 
to  be 
The 
adapted  to  the  type  and  level 
of  actors.  Additionally,  as  well 
as 
business 
awareness,  it  is  indeed  critical 
responders  are 
that 
first 
information 
provided  with 
regarding 
precursor 
such 
products, which may otherwise 
be  overlooked  during  normal 
routine  searches,  enquiries  or 
activities. 

tailor-fit  to  address  all  sorts 
of 
and 
actors 
updated continuously. 

different 

From  a  cost-perspective,  it 
may  be  more  efficient  and 
effective  to  concentrate  on 
those  stakeholder  groups 
where  such  information  can 
make a real impact. 

Cost  estimate  based  on  six 
different  stakeholder  groups 
transport 
(manufacturers, 
companies,  wholesale,  retail, 
first respondents and youth): 

Research  and 
information 
collection (preparatory work): 
50,000 euro 

Preparation  of  6  security 
information 
packages: 
120,000 euro 

Dissemination: 20,000 euro 

Reviews 
updates: 30,000 euro 

on 

need 

for 

EN 

Costs per MS: 220,000 euro 

Central 
guidance: 50,000 euro 

coordination  and 

Total  EU27:  5,990,000  euro 
in  the  first  year,  1,400,000 
euro in the following years. 

75 

EN 

 
  
S
4 

3 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

3 

No 

No 

Possibly,  as 
‘over-
enthusiastic’ 
or xenophobic 
reactions 
of 
certain  supply 
chain 
members 
could 
affect 
principles  of 
data-
protection 
and 
non-
discrimination 

Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

3 

3 

3 

for 

costs 

The 
the 
establishment  of  an  alert 
system  are  low  to  medium. 
They  would 
involve  some 
start-up  costs  relating  to  the 
development  of  a  central 
coordination 
the 
creation  of  specific  phone 
lines  and,  more  importantly, 
the  training  from  authorities 
to deal with the alerts. 

unit, 

Unit  set  up  costs:  20,000 
euro 

Staffing:  1  FTE  (registering 
alerts,  providing  information, 
etc) totalling 50,000 euro 

the 

Total  EU27:  1,890,000  euro 
in 
and 
1,350,000 
following 
years. 

first 
in 

year 

the 

Simple  means  should  exist  for 
anyone  within  the  supply  chain 
to  alert  the  relevant  national 
authority 
a 
transaction  or  theft  which  they 
suspect to have been made with 
the 
illegally 
of 
intention 
fabricating explosives. 

they 

see 

if 

2 

MS 

Actions  2  and  3  need  to  be 
implemented  together,  as  they 
depend  on  each  other.  The 
usefulness  of  these  measures 
is  high  -  The  lack  of  concern 
by certain suppliers of potential 
explosive 
is 
worrying.  

precursors 

This can be summed up in the 
example  of  Operation  Crevice 
during  2004.  The  conspirators 
had  purchased  600kgs  of 
ammonium  nitrate  fertiliser  to 
construct improvised explosive 
devices and were keeping it in 
a  unit  at  a  public  self-storage 
facility. 
agricultural 
The 
the 
supplier  who  had  sold 
fertiliser  said  the  young  man 
who  had  bought  it  claimed  it 
for  his  garden.  He 
was 
admitted 
the 
that  he  knew 
quantity  was  far  in  excess  of 
the  amount  needed 
this 
circumstances but he had sold 
it anyway and informed no-one 
of the unusual circumstances.  

in 

the  PIRA  bombing 
During 
the  UK 
campaign  against 
mainland 
(see  McGladdery 
2006),  the  Metropolitan  Police 
established 
Operation 
Rainbow  to  systematise  the 
counter  terrorism  response  to 
changes  in  the  threat  level. 
Part  of  the  response  involved 
raising  awareness  amongst 
storage  providers,  lorry  hire 
accommodation 
companies, 

EN 

76 

EN 

 
  
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

S
4 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

letting agencies and landlords, 
them 
with 
providing 
police 
contact 
appropriate 
numbers 
details. 
and 
Operation  Rainbow  continues 
today and has been expanded 
to  provide  a  similar  coverage 
to  the  ongoing  terrorist  threat 
from  violent  jihadist  groups  or 
individuals.  

The operation could be utilised 
as  a  suitable  model  on  which 
to  base  a  similar  wider 
operational network across the 
Member  States 
(MS).  A 
potential  hurdle  to  overcome 
with 
recommendation 
would to identify and nominate 
a  suitable 
“national  central 
agency” to carry out this work. 
In  may  need  to  be  created  in 
MS 
this 
that  do  not  have 
capability 

this 

The awareness of staff in such 
businesses is critical and there 
have  been  a  number  of 
instances in different countries 
where  public  and  business 
awareness  has  been  decisive 
in  alerting  the  authorities  to  a 
potential  conspiracy  to  cause 
an  explosion  by  a 
terrorist 
group. 

3 

MS 

in 

the  past, 
For  example, 
information  was 
important 
received 
the  public 
concerning  such  preparations 
Irish 
the  Provisional 
by 
Republican  Army  (PIRA),  in 

from 

to 

should 
raise 

be 
Campaigns 
conducted 
staff-
awareness of the threat all along 
chain  amongst 
the 
formulators, 
manufacturers, 
distributors  and 
retailers  of 
precursors.  

supply 

EN 

3 

3 

3 

3 

3 

No 

low 

The  costs  for  an  information 
campaign 
to 
are 
medium,  depending  on  the 
type  of 
(e.g. 
leaflets  and  posters  or  using 
television  as  a  medium)  and 
its coverage. 

campaign 

The  campaigns  should  be 
based  on  the  research  and 
information  collected  under 
action  1,  to  save  costs.  No 
further  estimate  is  possible 
without  knowing  the  type  of 
campaigns  (posters,  flyers, 
website, television and radio, 

77 

the 

such 

if 

Only 
consequence
s 
of 
campaigns 
are 
described 
above. 

as 

Possibly, 
some 
environmenta
l  costs 
for 
printing  and 
distribution. 

EN 

 
  
 
 
and 

economic 

S1 

G
0 

S
2 

S
3 

S
4 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

Financial 
effects 

etc). 

Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

bulk 

purchasing 

relation  to  the  purchase  and 
storage  of  Ammonium  Nitrate 
then 
fertilizer,  which  was 
mixed with Fuel Oil to produce 
ANFO (Ammonium Nitrate and 
Fuel  Oil).  More  recently  (the 
trial  of  the  21/7  failed  suicide 
bomb  attacks  on  the  London 
Underground  and  a  bus), 
individual  members  of 
the 
public  had  concerns  regarding 
the 
of 
Peroxide  and  Acetone.  It  was 
they  were 
not  until  after 
contacted  by  the  police  who 
had  already  arrested 
the 
conspirators  that  they  voiced 
these  concerns. 
Information 
from a London rubbish cleaner 
who had noted a large number 
of  empty  Acetone  bottles  in 
2005, which helped identify the 
flat  used  by  the  bombers  to 
make their TATP (Tri-Acetone, 
Tri-Peroxide) explosives. 

However,  attention  needs  to 
be  given  to  a  wider  pool  of 
people  who  may  come  across 
explosive  precursors  during 
their 
recent 
business.  A 
example again occurred during 
Operation  Crevice.  A  female 
staff  member  of  a  self-storage 
company  joined  some  former 
colleagues  for  an  evening  out, 
when  one  of  them  mentioned 
the  storage  of  Ammonium 
Nitrate fertilizer by the PIRA in 
the  1990s.  She  then  recalled 
that  a  group  of  Asian  males 
this 
had  stored  600kgs  of 

EN 

78 

EN 

 
  
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

S
4 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

fertilizer  in  their  self-storage 
facility. As a consequence, the 
police  were  contacted.  This 
provided  a  critical  piece  of 
intelligence and hard evidence 
in an operation  which later led 
to  the  arrest  and  subsequent 
conviction  of 
for 
cause 
conspiring 
explosions.  Targets  allegedly 
were 
‘Blue-Water’ 
shopping  centre  in  Kent  and 
the  MoS  Nightclub,  London, 
amongst others.  

the  group 
to 

the 

Objective  3:  Improve  the  control 
over 
involving 
precursors 

transactions 

the 

benefits 

of 
Assessing 
creating  a  scheme 
for  each 
precursor  handled  by  the  retail 
sector, 
all 
labelled 
packaging  would  be 
with  a  code  specifying  that  the 
purchase  of  the  substance  may 
be subject to registration  

under 

which 

The  possibility  of  designing  a 
indicate 
European  symbol 
that the product  for retail sale is 
subject  to  registration  could  be 
considered. 

to 

9 

MS/ 
Commissi
on 

Low cost for study assessing 
the  benefits  of  such  a 
scheme,  around  100,000 
euro. 

0 

High  costs  if  all  products 
would  have  to  be  uniformly 
labelled  across  the  EU.  The 
amount  of  products  to  be 
labelled  for  handling  by  the 
retail sector is very high. 

creating 

The assessment may conclude 
that 
additional 
labelling requirements may not 
have  the  desired  impact.  Only 
if  such  labelling  was  carefully 
coordinated  with  the  recording 
of  the  corresponding  sales  it 
might prove useful, but again it 
may  prove  difficult  to  ensure 
uniformity  in  the  introduction 
and  enforcement  of  such  a 
system  across 
the  various 
Member  States.  Lessons  and 
experience  may  be  obtained 
from  the  existing  systems  in 
place,  regarding  the  transport 
and  storage  of  hazardous 
materials (HAZMAT) in the UK. 

No 

No 

Possibly, 
if 
the  labelling 
be 
would 
the 
same 
EU wide. 

outcome 

The 
the 
assessment may be that there 
are no particular benefits. 

of 

EN 

79 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

S
4 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

Objective  4:  Improve  the  control 
over explosives available on the 
market and pyrotechnic articles 

Launch a debate on the need to 
review 
the  classification  of 
“desensitized explosives”  

19 

Commissi
on/ MS 

This should be done with a view 
future 
to  making  sure 
transport 
(GHS-
system)  continue  to  cover  such 
substances. 

regulations 

that 

the 

type 

The  debate  is  very  useful  – 
these 
excluding 
of 
explosives 
list  of 
from 
dangerous goods could have a 
very negative effect as terrorist 
would  be  able  to  reconvert 
such  material  into  potentially 
dangerous compounds. 

Objective 
security of explosives facilities 

Improve 

5: 

the 

effective  Security 
Introduce 
Management 
Plans/Security 
Systems 
explosives 
at 
facilities (manufacturing, storing, 
distributing and using) 

all 

12 

14 

MS 

the 

that 

Ensure 
levels  of 
necessary  access  prevention 
and detection provisions in fixed 
facilities  should  be 
storage 
proportional 
risk  and 
should  be  subject  to  a  standard 

the 

to 

and 

sites 

distribution 

Most  manufacturing,  storage 
and 
in 
Member  States  have  security 
plans 
management 
systems  in  place.  These  often 
include  ‘interlocking  series  of 
in-depth  security  measures’.  It 
may prove a challenge to bring 
security  plans  and  measures 
up  to  the  same  level  in  all  EU 
thus  ensuring  a 
countries, 
level  of  security 
‘universal’ 
across the EU. 

the  action 

Low  costs  on  the  short-term 
as 
concerns 
starting  a  debate.  Low  costs 
also  in  the  longer  term  as 
this  would  not  mean  a 
the  present 
change 
transport 
situation 
regulations 
the 
substances).  

from 
(current 

cover 

could 

debate 

The 
be 
supported  by  one  event  at 
(see  also 
250,000  euro 
the 
and 
2) 
action 
development 
a 
of 
consultation  website  (20,000 
euro), totalling 270,000 euro. 

The  measure  may  be  costly 
for  end  users  as  these  are 
often  not  required  to  have 
effective  security  plans  and 
management 
in 
place.  Nearly  all  producers, 
and 
storage 
distribution 
channels  are 
already  required  by  law  to 
have  such  measures 
in 
place. 

systems 

facilities 

EN 

80 

1 

1 

No 

No 

No 

4 

4 

2 

No 

if 

Possibly, 
EU-wide 
statutory 
require-
ments 
would 
be 
put in place 

Possibly, 
some 
environmenta
l  costs  if  the 
systems 
would require 
in 
putting 
place 
additional 
security 
measures 
(e.g.  fencing, 
etc). 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

S
4 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

classification. 

Detection Measures 

Objective 1: Establish a scenario 
based  approach  to  identifying 

are 

It  is  stressed  that  pre-emptive 
measures 
equally 
important  in  countries  with  a 
low  level  of  threat  as  the  theft 
of explosives is a cross-border 
issue.  Making  measures 
proportional  may 
to 
those 
terrorists 
countries  with  relatively  lower 
security 
is 
levels. 
illustrated by the ETA thefts in 
France. 

focusing  on 

lead 

This 

In addition, consideration must 
be  given  to  the  issues  of  what 
the  classifications  should  be, 
who 
inspects  and  classifies 
each  facility  and  who  is  in 
overall  charge  in  each  MS  of 
the scheme. Once more, will it 
be voluntary or statutory? 

Finally,  as  already  highlighted 
for similar measures proposed, 
it  will  be  particularly  difficult  to 
put in place security plans and 
management  systems  in  end 
user  sites  (e.g.  quarries  and 
using 
construction 
explosives)  were  currently  no 
or little security measures may 
be required by Member States. 

sites 

The  action  may  have  a 
negative impact on S5. 

EN 

81 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
G
0 

2 

S1 

S
2 

S
3 

S
4 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

2 

2 

No 

No 

Possibly, 
some 
environmenta
l costs (flights 
other 
and 
in 
transport) 
case 
of 
meetings. 

Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

23 

Commissi
on/ MS 

work  priorities  in  the  detection 
field 

Setup  a  working  group  tasked 
with  developing  and  discussing 
detection  related  scenarios,  and 
then 
detection 
technology  requirements  for  the 
scenarios.  

identifying 

The  working  group  would  be 
composed of Member State and 
Commission representatives. 

that 

The  working  group 
is 
proposed  will  need  to  have 
clear objectives and work well-
defined  terms  of  reference  in 
order to ensure that it does not 
and 
lose 
momentum over time. 

relevance 

its 

of 

of 

threats. 

perpetrators 

This  action  is  to  consider  at  a 
strategic  level  the  origin  and 
IED, 
nature 
explosives, 
manufactured 
targets, 
etc. 
Whilst  it  is  certainly  beneficial 
to develop detection scenarios, 
the 
this  would  mainly  be 
responsibility 
national 
authorities,  with  the  help  of 
experts.  It  could  be  useful  to 
exchange 
and 
share  experiences  with  regard 
to  the  building  of  scenarios 
and 
of 
the 
detection 
technologies,  but 
less  advantageous  to  discuss 
in  detail  the  content  of  the 
(as 
scenarios 
these  should  be  confidential 
and  strictly 
refer  national 
contextual issues). 

identification 

themselves 

information 

It  would be highly important to 
link  the  working  group  to  all 
other 
activities 
networking 
proposed in the Action Plan  

Low  costs 
to  set  up  a 
working group and to ensure 
communication 
regular 
opportunities 
(meetings, 
virtual exchanges, etc). 

Set up and preparatory work: 
(e.g. 
study, 
background 
identification  of experts,  etc): 
50,000 euro. 

Creation  website 
forum: 20,000 euro 

/  virtual 

Inputs to scenarios : 10 days 
per  Member  State  at  400 
euro. 

Logistics  for  meetings:  (e.g. 
travel, 
subsistence, 
rooms): 
conference 
approximately 1,000 euro per 
person. 

Total: Based a working group 
of  30  persons:  208,000  euro 
(for one year of activity). 

Potential  economic  benefits 
on  the  longer-term,  due  to  a 
and 
appropriate 
more 
efficient  use  of  detection 
systems. 

is 
Create  a  matrix  of  what 
desired  and  of  what  is  currently 

24 

Commissi
on/ MS 

for 
Same  assessment  as 
Measure  23  above.  The 

to 
costs 
Low 
matrixes,  mainly 

develop 
related 

2 

2 

2 

No 

No 

No 

EN 

82 

EN 

 
  
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

S
4 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

in 

terms  of 

possible 
the 
detection  of  explosives  for  each 
of  the  scenarios  created  by  the 
working group. 

Objective 
2: 
minimum detection standards 

Developing 

for 

Develop  mechanisms 
the 
identification  and  dissemination 
of  good  practice  in  detection 
systems  and 
the  use  of 
detection equipment 

Part 
of 25  

Objective  3: 
exchange of information 

Improving 

the 

content of the matrix would be 
a strictly national responsibility, 
while  it  would  be  beneficial  to 
discuss  how  to  develop  such 
matrixes, what items to include 
depending  on  the  indications 
in the scenarios, etc. 

The industry may not be ready 
for minimum standards – more 
innovation  and 
investments 
are  needed.  In  addition,  the 
is  extremely 
detection  area 
wide,  what  kind  of  standards 
would  that  be?  And  why  are 
they  minimum  –  a  set  of 
standards would be better. 

to 

learnt 

It  would  be  useful 
first 
identify  good  practice  and 
lessons 
in  existing 
detection systems, for example 
in  aviation  security  which  is  a 
more  developed  area  which  is 
using standards for detection. 

such  as 

inputs 
human 
external expert involvement. 

internal 
and 

resources 

for 

inputs 

Expert 
the 
development of the matrixes: 
10 days per Member State at 
400  euro,  totalling  108,000 
euro. 

Potential  economic  benefits 
on  the  longer-term,  due  to  a 
more 
and 
appropriate 
efficient  use  of  detection 
systems. 

The  network  of  detection 
experts  discussed  under 
action  34  could  assist  in  the 
identification of good practice 
in  detection  systems  and 
their  use.  Each  of  the  10 
experts  could  be  requested 
to  input  10  days  at  400  euro 
to  map  and  analyse  good 
practice, thus totalling 40,000 
euro.  A  similar  exercise 
could  be 
launched  each 
year. 

1 

1 

1 

No 

No 

No 

EN 

83 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

2 

No 

No 

if 

Possibly, 
the 
information 
identified 
specific 
groups 
communities 
this 
affect 
principles 
non-
discrimination 

could 

or 

S
4 

3 

Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

Low  cost 
for  setting  up 
appropriate  communication 
protocols, 
and 
channels 
including  the  designation  of 
contact persons. 

3 

2 

Set-up  cost:  1,000  euro  per 
Member State 

Inputs:  0.2  FTE  per  year  per 
Member State 

Total:  297,000  euro  for  the 
first  year  and  270,000  euro 
for the subsequent years. 

at 

airports) 

Ensure that the security staff (in 
particular 
are 
provided  on  a  continuous  basis 
with  up-to-date  information  on 
relevant  parts  of  new  terrorist 
modi 
other 
appropriate threat information. 

operandi 

or 

For  airport  security,  this  should 
complement  the  obligations  for 
training  security  staff  set  out  in 
§12.2  of  the  Annex  to  the  EU 
2320/2002 
Regulation 
establishing  common  rules  in 
the field of civil aviation security 

42 

MS 

Ensuring  (airport)  that  security 
staff  is  immediately  updated 
terrorist 
regarding  any  new 
TTPs  (Tactics,  Targets  and 
Planning)  is  essential  and  will 
have a positive impact in terms 
of  increasing  the  security  of 
explosives. The EWS could be 
used 
relevant 
extract 
to 
information from. 

audit 

exactly 

However, much as in the case 
of  an  EU  Bomb  Database, 
rather  than  re-creating  what 
already  exists, 
it  would  be 
to  carry  out  an 
beneficial 
Member  State 
to 
establish 
what 
communication  structures  are 
already in place for the sharing 
of  such 
information.  These 
can,  if  needed,  be  expanded 
and 
developed. 
Inevitably,  with  such  sensitive 
information, 
most 
‘practitioners’  in  the  field  of 
counter-terrorism  may  rather 
relay 
information 
informally  and  bi-laterally  to  a 
foreign  colleague  they  trust, 
rather 
in  a 
than  placing 
information  system, 
central 
where  access 
inevitably 
wider.  

further 

such 

is 

it 

It  will  also  be  important  to 
focus  on  security  staff  at 
international  train  stations  and 
ferry points, as these have less 
security measures in place and 
may  also  be  subject  of  a 

EN 

84 

EN 

 
  
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

S
4 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

Assess  and 
necessary 
regards 
training 
information/feedback 
manufacturers 
of 
solutions 

improve  where 
the  situation  as 
availability 
of 
other 
and 
for 
detection 

the 
data 

30 

Commissi
on/ MS 

terrorist attack. 

Feedback  to  manufacturers  is 
very important. The concept of 
‘training’  makes  little  sense  in 
this  context,  but  providing 
manufacturers with operational 
data 
actually 
happens)  would  help  them  to 
improve  the  performance  of 
their equipment. 

(i.e.  what 

Low  cost 
to  collect  and 
prepare  feedback  and  data 
to  manufacturers,  e.g.  in  the 
form of reports and statistics. 

2 

2 

1 

No 

No 

No 

Create  an  end-user 
handbook concerning detection 

focused 

33 

Commissi
on/MS 

trying 

The  handbook  would  provide 
advice  to  end  users,  in  the 
form  of  a  user  manual  on 
detection systems in general. It 
should  not  include  information 
on 
the 
the  performance  of 
detection system that could be 
to  anyone 
useful 
to 
explosives  material 
avoid 
Regular 
detected. 
being 
updates  would  be  required, 
and  for  this  purpose  it  may  be 
best  to  use  a  virtual  tool.  An 
analogous 
is 
currently  in  use  for  aviation 
security.  The  handbook  would 
the  strategic  and 
enhance 
targeted 
of 
detection tools, thus increasing 
the  probability  of  detection  of 
terrorists  and  other  criminals 
and  improving  the  chances  of 
prevention and intervention. 

placement 

document 

to 

related 

Low  cost 
the 
development and updating of 
the  handbook.  Some  inputs 
from  external  experts  and 
manufacturers  of  detection 
technologies. 

2 

2 

1 

No 

No 

Possibly, 
some 
environmenta
in 
l 
costs 
of 
case 
printing. 

Development 
handbook: 50,000 euro 

of 

the 

Expert 
its 
inputs 
development: 20 days at 400 
euro, totalling 8,000 euro 

to 

Annual 
euro. 

updates: 

20,000 

Total:  78,000  euro  for  the 
first  year  and  20,00  for  the 
subsequent years. 

As  a  virtual  tool,  which  can 
in 
also  be  easily  updated, 
larger 
combination  with 

the 

EN 

85 

EN 

 
  
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

S
4 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

Bomb 
European 
virtual 
Database 
including 
(also 
action 32 above) it would be a 
relevant  and  useful  product. 
There  may  be  benefit 
in 
carrying  out  an  assessment  of 
the  needs  of  the  future  users 
of the handbook. 

in 

proposed 

Any 
networking 
activity  should  be  based  on 
existing  cooperation  initiatives, 
where  these  are  in  place.  It 
would  also  be  important  to 
ensure  that  the  network  does 
not  work 
‘isolation’  and 
adopts  a  very  practical  focus. 
Regular  encounters  with  other 
networks  should  be  organised 
(e.g.  working  group  of  experts 
of 
for 
the 
detection 
the 
network  of  EOD  units  and  the 
wider 
on 
vertical 
explosives) 
working  groups  should  be 
organised  combining  detection 
experts  with  bomb  experts, 
industry, etc. 

development 
scenarios, 

conferences 
and 

Create  a  network  of  experts  on 
the detection of explosives 

34 

Commissi
on/ MS 

EN 

experts 

to  set  up  a 
Low  costs 
identifying 
network, 
and 
appropriate 
organise 
(virtual) 
regular 
meetings.  Some  inputs  for 
expert 
the 
fees 
preparation of reports, etc. 

for 

Set up and preparatory work: 
briefing  materials, 
(e.g. 
identification  of experts,  etc): 
50,000 euro. 

Creation  website 
forum: 20,000 euro 

/  virtual 

Annual  inputs:  20  days  per 
expert at 400 euro 

reporting 

and 
Summary 
analysis:  10,000  per  report, 
two reports per year. 

travel, 

Logistics  for  six  meetings: 
subsistence, 
(e.g. 
conference 
rooms): 
approximately 1,000 euro per 
person. 

Total: Based on a network of 
10  persons:  180,000  for  the 
first  year  and  130,000  euro 

86 

2 

1 

2 

1 

No 

No 

Possibly, 
some 
environmenta
l costs (flights 
other 
and 
in 
transport) 
case 
of 
meetings. 

EN 

 
  
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

S
4 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

for the following years. 

Objective  4:  Establish  EU-wide 
certification,  testing  and  trialling 
schemes 

for 

Develop  mechanisms 
the 
identification  and  dissemination 
of  good  practice  in  detection 
systems  and 
the  use  of 
detection equipment 

the  need 

the 
Assess 
development 
standards 
concerning  certification,  testing 
and trialling processes. 

for 

of 

Objective  5:  Improve  the  usage 
of  detection 
in 
specific locations 

technologies 

Improve  the  use  of  detection 
technologies  at  airports,  railway 
stations 
public 
facilities. 

other 

and 

in 

this 
Further  developments 
field  should  be  supported.  The 
situation  should  be  evaluated 
and  assessed  on  a  continuous 
basis,  and  updated  as  the  need 
arises. 

EN 

Part 
of  27 
(sam
e  as 
Part 
of 25) 

29 

Commissi
on/ MS 

31 

Commissi
on/ MS 

of 

Assessing  the  need  for  the 
development 
such 
standards  is  useful  –  only  the 
results  of  the  assessment  will 
tell. It will be important to learn 
(national) 
from 
standards  that  are  already  in 
place at national level, e.g. for 
laboratory  testing,  certification, 
etc.l 

existing 

level 

higher 

The measure proposed is very 
generic,  as  it  is not  clear  what 
this  would  entail.  Given  the 
overall 
of 
regulation  and  coordination,  it 
is  likely  that  lessons  can  be 
learned 
the  aviation 
sector. It is indeed evident that 
overall  security  measures  and 
the  use  of  detection  is  much 
lower 
sectors, 
in 
in  harbours  and 
particularly 

other 

from 

See Part of 25 above. 

1 

1 

1 

No 

No 

No 

Low  costs 
launch  a 
to 
feasibility  study  and  ensure 
that 
are 
the 
integrated 
the  work 
programme. 

lessons 

in 

Estimated costs for feasibility 
study: 100,000 euro. 

Difficult  to  estimate  the  cost 
level  as  the  action  is  very 
generic. However, increasing 
the  number  of  detection 
systems  in  airports,  railway 
stations  and  public  facilities 
would entail a very high cost 
as 
is  very 
costly  and  as  they  require 
well-trained 
staff.  These 
costs  may  in  some  cases 
outweigh the benefits. 

the  equipment 

87 

1 

1 

No 

No 

No 

2 

1 

2 

2 

No 

No 

No 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

S
4 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

Evaluations 
and 
assessments  of  the  need  for 
detection technologies would 
low  cost,  as 
constitute  a 
likely 
these  would  mostly 
concern 
and 
launching 
updating studies. 

Costs  for  feasibility  studies 
for  each  sector:  100,000. 
Based on a coverage of four 
railway 
sectors 
(airports, 
high-
stations, 
profile public places) the total 
costs  would  be  400,000 
euro. 

harbours, 

‘high-risk’ public facilities. 

any 

such 
Unfortunately, 
increase 
detection 
in 
technologies  and  measures 
is  almost 
there 
introduced, 
invariably 
concomitant 
a 
impact  on  the  time  taken  for 
security  checks,  the  flow  of 
passengers 
/  visitors,  and 
consequently the effectiveness 
of the transport networks. This 
was  most  recently  observed 
the  disruption  of  air 
during 
transport 
the 
caused 
increased  security  measures 
introduced  following  Operation 
Overt  in  the  summer  of  2006. 
This  plot  involved  an  alleged 
conspiracy  by  a  group  of 
British  violent 
to 
smuggle 
explosives 
liquid 
onboard  a  number  of  trans-
Atlantic 
the 
these 
intention  of  downing 
aircraft in a coordinated, mass 
casualty suicide attack.  

flights,  with 

jihadists 

by 

airport 

including 

security 
Rigid 
the 
measures, 
questioning  of  passengers 
while  queuing,  and  the  hand 
luggage, 
searching  of  hold 
along  with 
standard 
Rapiscan  X-raying  of  such 
luggage, are standard practice 
in  Israel,  but  this  necessitates 
a minimum three hour check in 
period,  and  its  intrusiveness 
may  not  be  acceptable  to  the 
public  in  many  of  the  Member 

the 

EN 

88 

EN 

 
  
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

S
4 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

States.  

Concerns  have  been  raised 
that cargo carried in passenger 
aircraft  is  not  subject  to  the 
same  screening  as  passenger 
luggage  also  stored  within  the 
cargo 
this 
hold.  Clearly 
undermines the whole purpose 
of  aviation  security  screening, 
with  potentially  devastating 
results,  and  is  a  loophole  that 
needs 
closed. 
Consequently  cargo  must  be 
subjected  to  the  same  level  of 
security  screening  as  hand 
and hold luggage in passenger 
aircraft. 

be 

to 

Finally,  however,  one  must 
take  account  of  the  extremely 
low numbers of explosives and 
explosive  materials  which  are 
actually  being  found  by  using 
detection  technologies  and  of 
the high costs involved. 

Preparedness  and 
measures 

response 

Improve 

the 
Objective 
1: 
exchange  of 
information  and 
best-practices  among  relevant 
Member State authorities 

Establish  a  European  EOD 
Network 

38 

MS/Europ
ol/ 

The  system  should 
facilitate 
trust 
information  sharing  and 
building.  It  should  contribute  to 

Commissi
on 

The 
be 
network  would 
beneficial  provided  it  is  based 
on existing cooperation models 
(also 
and  more 
informal  forms  of  networking) 
and  remains  flexible.  It  would 

bilateral 

Medium  cost  depending  on 
the  activities  of  the  network, 
the  number  of  meetings 
organised  and  the  outputs 
reporting, 
(e.g. 
expected 
sessions, 
training 

3 

3 

3 

2 

No 

No 

EN 

89 

Possibly, 
some 
environmenta
l costs (flights 
other 
and 
in 
transport) 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

S1 

G
0 

S
2 

S
3 

S
4 

S
5 

S
6 

Need 
to 
change  EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

case 
meetings. 

of 

particularly  favour  information 
sharing  and 
trust  building, 
which are two items which are 
at present underdeveloped. 

dissemination0 

It  would  indeed  be  beneficial 
to support the start-up phase 
of  the  network  through  EU 
funding,  as  these  may  be 
relatively high. 

Set up and preparatory work: 
(e.g. 
study, 
background 
coordination 
setting 
structures, 
200,000 
euro. 

etc): 

up 

Creation  website 
forum: 20,000 euro 

/  virtual 

Inputs to identification of best 
practice  and  other  activities: 
20 days per Member State at 
400 euro. 

Central 
organisation 
sessions, 
updates 
100,000 euro. 

coordination, 
training 
of 
of 
reporting: 

preparation 
and 

Logistics  for  meetings:  (e.g. 
subsistence, 
travel, 
conference 
rooms): 
approximately 1,000 euro per 
person. 

Total: Based on a network of 
27 persons: 543,000 euro for 
the first year and 323,000 for 
the subsequent years. 

90 

EN 

of 

identification 

the 
best 
practice, the organisation of joint 
training  exercises,  and  keeping 
EOD units up to date concerning 
the 
latest  developments  of 
relevance to the sector. 

The  network  should  be  made 
to  all  EOD-Units 
available 
(police, 
and 
governmental 
military)  dealing  with  explosives 
with the MS. 

to 
The  use  of  EU 
establish  the  network  should  be 
assessed. 

funding 

EN 

 
  
 
 
on 

Effects 
fundamental 
rights 

Environment
al effects 

No 

No 

change 
EU 
legislation 

Possibly, 
to  make 
informatio
n 
compulsor
y. 

inputs 

Policy option 3 – Intermediate option 

Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
O 

Horizontal Measures 

S1  S2  S3  S4  S5  S6  Need 

to 

1: 

Objective 
the 
exchange  of  timely  information 
and best practices 

Improve 

Create  a  European  Bomb  Data 
System 

35 

Commissi
on 

The  system  should  provide  a 
common EU instrument enabling 
authorised  governmental  bodies 
at  EU  and  Member  States  level 
to  have  24/7  access  to  relevant 
information 
incidents 
involving explosive devices. 

on 

/Europol/M
S 

36 

37 

in 

least  all  operational  EOD 
At 
the  Member  States 
units 
the 
should  have  access 
database.  Other 
competent 
authorities in the Member States 
should  also  be  given  access  in 
line with national law.  

to 

Competent units or bodies of the 
Member  States 
should  be 
strongly  obliged  to  provide  all 
necessary 
for 
information 
inclusion in the database. 

EN 

is 

‘just’ 

important 

managed 

It 
to  clarify 
whether the action proposes a 
the 
wider  system  or 
development  of  the  European 
Bomb  Database.  The  creation 
of  a  European  Union  Bomb 
Database, 
by 
Europol for the benefit of EOD 
and  other  security  officials  in 
the Member States can have a 
positive  impact.  The  system 
should  be  linked  to  the  Early 
Warning 
(EWS) 
System 
mentioned  under  action  39 
above  to  avoid  overlaps  of 
information  and 
identify 
gaps.  

to 

The  use  of  hydrogen  peroxide 
for  the  bombings  in  the  UK 
shows however the benefits of 
in  place  EWS  and 
putting 
other 
information 
central 
systems  –  if  Member  States 
this 
had 
information 
to 
prevent the criminal use of this 
product. 

timely  access 

it  may  help 

to 

Rather  than  ‘re-inventing  the 
it  may  be  worth 
wheel’, 

2 

2 

1 

1 

to  medium 

costs 
Low 
the 
involving  setting  up 
its 
ensuring 
database, 
other 
integration 
with 
in  place 
systems,  putting 
high 
levels 
security 
preventing  access  by  non-
and 
authorised 
Inputs 
ongoing  updating. 
State 
from 
authorities 
other 
designated  actors  to  insert 
information. 

Member 
and 

parties 

information 

Cost efficiencies on the long 
term:  provided  the  database 
includes 
on 
incidents around the globe, it 
will  help  Member  States  to 
quickly  access  centralised 
information 
issues 
occurring  in  third  countries 
rather than having to rely on 
bilateral 
intelligence 
collection. 

for 

Set-up  and  organisation: 
200,000  euro 
(database, 
virtual access, sedurity) 

Internal  staffing:  1.5  FTE, 

91 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
O 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

totalling 75,000 euro 

Inputs:  average  20  days  per 
Member State per year at an 
average  fee  of  400  euro, 
totalling  216,000  euro  per 
year 

Outputs: 
reporting, 
(e.g. 
analysis) 4 summary reports 
of  10,000  euro, 
totalling 
40,000 euro. 

Total:  531,000  for  the  first 
year,  313,000  euro  for  the 
following years. 

its 

counter-part 

formal  and 

checking  across  the  EU  to 
establish  exactly  what  other 
Bomb  Databases  exist,  and 
informal 
what 
communication 
links  already 
exist  between  various  EOD 
units  in  the  Member  States. 
For  example,  at  Scotland 
Yard,  within  the  Metropolitan 
Police 
Counter-Terrorist 
Command  (CTC),  there  is  an 
extensive  Bomb  Data  Centre, 
with  a  wealth  of  information 
and  years  of  experience  (as 
does 
in 
Ireland).  Similarly,  there  is  an 
Israeli  National  Police  Bomb 
Data  Centre  in  Tel  Aviv.  This 
situation  must  also  occur  in 
other  Member  States  e.g. 
France, 
Italy. 
Clearly,  as  well  as  police  and 
EOD 
their 
Explosives  Officers  (EXPOs) 
and 
Databases, 
attention  would  need  to  be 
given  to  the  various  Member 
States  military  EOD  units  and 
the  expertise  developed  by 
their  Ammunition  Technical 
Officers  (ATO)  if  they  act  in 
this  capacity  to  support  the 
police. 

Germany, 

Bomb 

units 

with 

Making  the  inputs  compulsory 
would  certainly  increase  the 
benefits  of  the  system.  Some 
Member  States  may  not  wish 
to  input  a  high  extent  of  detail 
in  the  system  or  would  not 
have  sufficient  resources  to 

EN 

92 

EN 

 
  
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
O 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

Prevention Measures 

2: 

Improve 

Objective 
regulation 
precursors  available  on 
market 

the 
explosives 
the 

of 

The  establishment  of  a  system 
regulation  of 
concerning 
explosives  precursors  available 
on the market. 

the 

4 

Commissi
on/ MS 

Such  a  system  should  include 
the  establishment  of  a  Standing 
tasked 
Committee  of  Experts 
risks 
with 
the 
identifying 
associated 
various 
precursors  and  recommending 
appropriate  actions 
the 
Commission.  The  Committee 
should  consider 
following 
issues: 

with 

the 

to 

of 

Development 
suitable 
additives  and  promotion  of  the 
use  of 
to 
precursors  in  order  to  prevent 
their use in explosives, when it is 
technically possible. 

these  additives 

Restrictions  on  concentration 

EN 

provide  inputs.  Some  financial 
support could be envisaged. 

The scoring of S5 only applies 
includes 
if 
the  database 
information  about 
incidents 
around the globe. 

There  is  no  information  on 
what  the  wider  outline  of  this 
system  would  be.  In  addition 
to 
the  establishment  of  a 
Standing  Committee,  what 
else  would 
system 
include? 

the 

In  principle,  any  of  the  issues 
listed  could  have  a  useful 
impact  on  enhancing 
the 
security 
homemade 
explosives and IEDs.  

of 

Note  that  point  4  would  be 
redundant  if  the  recording  of 
transactions  etc  as  mentioned 
in recommendation 7 would be 
put in place. 

that 

would 

i.e.  developing 

The  costs  of  any  decision 
that  the  Committee  would 
make, 
the 
regulates 
system 
precursors, 
be 
enormous, 
potentially 
especially 
such 
measures  are  both  applied 
downstream (to retailers and 
end users) and upstream (to 
other  manufacturers  and 
industrial users). 

when 

on  EU 

The  chemical  sector  has  an 
economic  important  position 
in  several  Member  States. 
The  impacts  of  any  such 
and 
measures 
national  economy  would 
have 
to 
separate  feasibility  study.  In 
addition,  the  impact  on  the 
effectiveness  of  such  ‘dual 
purpose’  chemicals  in  their 
primary  industrial  role  will 

to  be  subject 

3 

2 

3 

3 

No 

Possibly, 
only  as  a 
con-
sequence 
of 
subseque
nt 
decisions 
(e.g. 
introduce 
a 
ban 
concentrat
ed acids). 

to 

Some 
subsequent 
decisions 
could 
actually  lead 
to 
environment
al and safety 
benefits 
(e.g. 
concentratio
ns 
chemicals, 
bans 
concentrate
d acids) 

lower 

on 

of 

93 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
O 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

concerning  the  sale  of  certain 
precursors to end-users. 

A complete ban on concentrated 
strong  acids  to  EU  consumer 
markets 
(non-professional 
markets)  when  a  substitute 
giving an equal use is technically 
possible:  sulphuric,  hydrochloric 
and nitric acids in particular. 

Introduction  of  a 
voluntary 
market  surveillance  scheme  for 
ammonium  nitrate  fertilizers  and 
restricting 
the  sale  of  high 
nitrogen fertilizers to the general 
public. 

Limiting  the  availability  of  pure 
nitromethane 
the  general 
to 
public.  It  should  be  available  to 
industrial 
via  a 
customers 
suitable  customer  qualification 
scheme. 

Restrictions  on  access  of  the 
general 
to 
unphlegmatized sodium chlorate 
(weed killer). 

public 

The  work  of 
the  Committee 
should  take  into  account  the 
detailed  measures  proposed  in 
the  Explosives 
Annex  2  of 
Security  Experts  Task  Force 
report. 

Objective  4:  Improve  the  control 
over  explosives available  on  the 

have  to  be  assessed.  Many 
representatives 
industrial 
expressed their doubts as to 
the 
feasibility  of 
changing  the  nature  of  a 
number of chemicals. 

technical 

(e.g. 

Set  up  and  preparatory 
background 
work: 
study, 
identification 
Committee  members,  etc): 
50,000 euro. 

Expert  inputs:  10  days  per 
issue  (6  issues  in  total)  per 
expert (10 experts). 

of 
Preparation 
recommendations  on  each 
issue 
and 
(summary 
analysis):  20,000  euro  per 
issue. 

travel, 

for  4  meetings: 
Logistics 
subsistence, 
(e.g. 
conference 
rooms): 
approximately  1,000  euro 
per person. 

Total: Based a Committee of 
10  persons:  270,000  euro 
(for one year of activity). 

EN 

94 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
O 

S1  S2  S3  S4  S5  S6  Need 

to 

2 

2 

1 

1 

21 

MS/ 
Commissi
on 

market and pyrotechnic articles 

regulating 

Ensure 
that  each  Member 
States  has  formal  systems  for 
authorising, 
and 
the  manufacture, 
licensing 
use 
sale, 
storage, 
and 
explosives 
of 
possession 
including by private persons.  

This shall apply to companies as 
well  as 
to  non-commercial 
activities. 

sale 

storage, 

Many  countries  where  there 
has  been  or  continues  to  be 
an active threat from terrorism 
already  have  strict  controls  on 
the 
and 
possession of explosives, both 
commercial  and  military.  It  is 
therefore  more  a  case  of 
ensuring 
that  all  Member 
States,  particularly  the  newer 
ones,  adopt  the  best  practice 
in 
found 
these  countries, 
which 
is  beneficial.  Also, 
private  persons  are  in  a  few 
from 
countries 
It 
licensing 
would  be  beneficial  to  always 
include  private  persons  in  the 
authorisation, 
formal 
regulation 
licensing 
and 
processes.  Again,  most  focus 
should  be  placed  on  end 
users, as security measures in 
this  sector  appear  to  be  much 
lower  than  those  put  in  place 
for manufacturers. 

requirements. 

exempt 

of 

this 

setting 

Low 
costs. 
to  medium 
Countries  that  already  have 
extensive  formal  systems  in 
financially 
place  will  not 
suffer 
action. 
However, in countries where 
such 
are 
systems 
underdeveloped,  authorities 
to  substantially 
will  have 
invest 
up 
in 
licensing, 
for 
procedures 
authorising  and  regulating 
the  whole  supply  chain. 
Companies  will  most  likely 
be charged for the additional 
procedures.  As  mentioned 
earlier,  placing  high  security 
requirements  on  end  users 
may  entail  a  high  cost,  as 
their  use  and  possession  is 
not  as  regulated  as  for  the 
other sectors. 

on 

Effects 
fundamental 
rights 

Environment
al effects 

No 

No 

change 
EU 
legislation 

Possibly, if 
EU-wide 
procedure
s  were  to 
be 
proposed. 

With  regard  to  the  storage  of 
explosives,  most  of  the  stolen 
explosives  have  been  legally 
produced  and  are  of 
the 
commercial  type,  often  taken 
factories  or  mining 
from 
quarries 
(Gander  1989).  A 
classic example of the latter is 
the 
tonnes  of 
explosives  from  a  quarry  in 
Plevin,  France  in  1999,  during 
a  joint  operation  between  the 

theft  of  8.5 

EN 

95 

EN 

 
  
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
O 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

Basque  separatist  ETA  and 
the  Breton  ARB,  which  was 
later  used  in  a  series  of  fatal 
bombings (Baud 2003).  

Interestingly, the historical IRA 
traditionally  associated 
was 
theft  and  use  of 
the 
with 
quarrying  dynamite.Recently 
the PIRA is increasingly linked 
with  both  the  military  grade 
explosive,  Semtex, 
plastic 
in  Czechoslovakia 
produced 
and  shipped  to  them  by  Libya 
in  vast  quantities  in  vessels 
such  as 
the  MV.  Claudia, 
Marita  Ann  and  the  Ecksund 
(Moloney  2002).  As  well  as 
using  it  as  an  explosive  on  its 
own, 
to 
initiate  the  detonation  of  the 
much 
of 
‘homemade’ explosive (usually 
Ammonium  Nitrate  and  Fuel 
Oil  (ANFO)  employed  in  the 
lorry  bombi  attacks  in  London 
in 
the  early  1990s  and 
Manchester  in  1996  (Harnden 
2000) .  

it  was  also  used 

quantity 

larger 

Likewise,  ETA  have  regularly 
stolen and utilised the Spanish 
produced  quarrying  explosive 
known  as  “Goma  2  ECO”  for 
their  bomb  attacks  (Alexander 
et.al.  2001).  This  widely  used 
commercial  explosive  was 
also 
train 
bombings of April 2004 by the 
jihadist  Madrid  cell, 
violent 
who traded a quantity of drugs 

the  Madrid 

in 

EN 

96 

EN 

 
  
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
O 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

with  a  criminal  group  in  return 
for  a  supply  of  the  previously 
stolen 
(Vidino 
explosives 
2006).  

13 

MS 

Objective 5: Improve the security 
of explosives facilities 

Introduce  an  obligation  for  the 
relevant  national  authorities  to 
keep  explosives  manufacturers 
and  distributors  informed  as  to 
the regional threat at all times 

Response  plans  should  be 
developed  tuned  to  the  level  of 
alert present. 

However, 
assessments 

In  principle,  full  awareness  of 
the  level  of  threat  would  be 
at 
beneficial. 
present 
of 
regional  threats  do  not  exist. 
The  efficacy  of  developing  a 
that  of  a 
new  concept, 
“regional 
threat” 
remains unproven. 

level  of 

Unless there is a very specific 
the  use  of  regional 
threat, 
It 
alerts 
is  unnecessary. 
taken 
should  also  be 
into 
explosives 
account 
manufacturers  and  distributors 
may  not  be  able  respond  fast 
to alerts either. 

that 

Threat  assessments  are  a 
national  responsibility.  Various 
different 
countries 
have 
systems,  which 
not 
do 
necessarily  link  the  level  of 
threat with a set level of alerts 
and  responses.  For  example, 
in  the  UK  there  are  various 
threat levels, but the alert level 
kept 
and 
responses  are 
In  France, 
separate. 
the 
system  matches 
Vigipirate 
to  a 
various 

threat 

levels 

1 

1 

1 

No 

If based on existing systems 
in  the  Member  States,  costs 
are  likely  to  be  low.  Some 
start-up  costs  would  be 
up 
to 
required 
communication 
and 
coordination  channels  with 
companies, making sure that 
the right persons will receive 
the information on the threat. 

set 

costs 

might 

indirect 

to 
The 
companies 
be 
medium,  especially  when  a 
response  is  required  (e.g.  a 
stop  on  transport,  access 
prevention 
in  production 
sites, etc). 

No 

Possibly, if the 
information  on 
threats 
identified 
specific 
groups 
communities 
this 
affect 
principles  non-
discrimination 

could 

or 

EN 

97 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
O 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

specific 

‘traffic  light’  response  scale, 
pre-planned 
with 
measures 
response 
introduced  at  each 
level 
(DGPN 2005). 

the  wording  of 

Finally, 
the 
measure  could  be  changed  to 
increased  threat  –  there  is  no 
need  to  inform  actors  on  the 
threat  level  when  this  is  at  a 
low 
is 
higher,  manufacturers  and 
distributors  would  be  advised 
to 
their  security 
measures as they see fit. 

increase 

threat 

level. 

the 

If 

20 

MS 

in 

the 
Raw  materials  used 
manufacture  of  bulk  explosives 
and  finished  product  should  be 
periodically  accounted  for  and 
reconciled  as  approved  by  the 
National Authorities. 

to  all 

This  applies 
factories 
manufacturing  bulk  explosives. 
The  relevant  periods  should  not 
be long so that any losses, thefts 
are 
inconsistencies 
and 
recognized 
as 
as 
possible. 

quickly 

already 

attention 
is 

raw 
on 
Higher 
beneficial. 
materials 
reconciling 
Accounting  and 
exist 
systems 
However, 
feasibility  of 
requiring authorities to take an 
active role in reconciliation and 
approval  of  quantities  of  raw 
materials appears to be low.  

the 

It  is  difficult  to  estimate  the 
costs of the measure without 
knowing  their  extent.  Low 
costs 
in  many  Member 
States as these systems are 
already  existing  and  of  high 
to  high 
quality.  Medium 
for  countries  which 
costs 
substantially 
have 
improve 
systems, 
their 
develop  new  procedures 
human 
and 
resources 
for  control  and 
enforcement. 

allocate 

to 

Improve  the  security  of  Mobile 
Explosive  Manufacturing  Units 
(MEMUs) 

15, 16, 
17 

Commissi
on/ MS 

The  following  specific  actions 
should be undertaken: 

Each  MEMU  should  have  at 

There are little known cases of 
the 
thefts  of  MEMUs  and 
benefits  of  this  measure  could 
therefore  be 
limited.  Most 
countries 
that  use  MEMUs 
have  modern  vehicles  and 
security  measures 
good 
already in place. For example, 

The  number  of  MEMUs  in 
is 
the  Member  States 
relatively  low.  For  example, 
there  are  5  units 
the 
Czech Republic and 10 units 
in  Sweden, 
in 
the  country  with  a 
1998, 
share 
15% 

market 

latter, 

the 

in 

1 

1 

1 

No 

No 

No 

1 

No 

No 

Possibly, if 
there  is  a 
need 
to 
integrate 
these 
requireme
nts 
transport 

in 

EN 

98 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

related 
legislation. 

on 

Effects 
fundamental 
rights 

Environment
al effects 

Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
O 

least  two  independent  systems 
the  amount  of 
for  recording 
explosives produced 

Each  MEMU  should  be  fitted 
with  process  locks  to  prevent 
unauthorised use 

Loaded  MEMUs  should  be 
parked  on  a  site  which 
is 
guarded or monitored when they 
are not in use. 

Objective 6: Improve the security 
vetting of personnel 

that 

there 

the UK has specific guidelines 
for  MEMUs  and  Sweden  has 
anti-theft  systems 
in  place. 
However,  the  Member  States 
indicated 
are 
alternative  ways  to  make  the 
units  more  secure,  such  as 
the 
camera  surveillance  on 
vehicles  and  other  types  of 
locks.  The  ones  proposed  are 
not necessarily considered the 
most appropriate. 

Finally,  several  manufacturers 
indicated  that  it  is  practically 
impossible  to  correctly  record 
the  amount  of  explosives 
produced  as  there  is  always 
residue left in the units. 

concerning 
the 
manufacturing  of  explosives 
(ranking third, after Germany 
with  22%  and  Spain  21%). 
In addition, in some Member 
States  onsite  mixing  is  not 
allowed. 

The costs for improving their 
security  would  be  relatively 
low,  as  the  units  are  very 
in  high 
expensive  and 
in 
demand. 
many  countries  the  security 
measures  already 
include 
those proposed in the Action 
Plan. 

In  addition, 

10,000 

of  MEMUs 

Average  additional  cost  per 
MEMU: 
euro 
(including  monitoring  and 
average 
guarding). 
The 
number 
is 
estimated  at  7  per  country. 
When  calculating  that  they 
in  15 
would  be  used 
total 
Member  States, 
costs 
their 
for 
security  would  be  around 
1,050,000  euro.  Ongoing 
monitoring  and  guarding 
would  cost  around  500.000 
euro per year. 

the 
improving 

All  personnel  employed  in  the 
storage, 
manufacturing, 
of 
distribution 

and 

use 

11 

MS 

Most  Member  States  have 
vetting  requirements  in  place 
handling 
for 

persons 

Some  initial  data:  Sweden: 
20  major  manufacturers  – 
and 
commercial 
both 

1 

1 

1 

1 

No 

Possibly, 
depending  on 
/ 
the  content 

No 

EN 

99 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
O 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

explosives  should  be  vetted 
relevant 
(external  checks  by 
national 
under 
authorities 
applicable  national  regulations) 
and  hold  a  formal  authorisation 
to have access to explosives. 

explosives.  The  UK, 
for 
example, requires a license for 
the  acquisition  of  explosives, 
while  in  Sweden  a  license  is 
needed for handling them.  

military. Most companies are 
not  very  large,  around  50-
200  staff  members,  with 
some  exceptions  of  up  to  a 
1000 – 2000. 

to 

increase 

extensive 

While 
it  would  be  a  good 
the 
measure 
security  of  explosives,  vetting 
may prove difficult to establish 
at  a  uniform  level.  While  at 
present  some  countries  carry 
background 
out 
checks  on  an  employee, 
only 
others 
scarce 
to  such  concerns, 
attention 
often 
a 
requiring 
declaration  that  the  person  in 
question  has  not  committed 
any related crimes.  

only 

pay 

checks  on 

These  different  concepts  of 
vetting  is  highlighted  by  the 
the  UK,  where 
example  of 
there  are  two  key  levels  of 
vetting. 
vetting” 
“Negative 
involves  basic  background 
database 
the 
individual  to  ensure  they  do 
not  have  detrimental  criminal 
convictions  or  a  County  court 
judgement against them, while 
“Developed  vetting”  entails 
through 
investigation 
active 
and 
detailed 
friends 
interviews  of 
and  employers.  While 
the 
latter  gives  a  greater  level  of 
certainty  and  hence  level  of 
is 
clearance, 
time 
expensive 

enquiries 
family, 

the  process 

and 

EN 

Around  2,000  licenses  have 
been given for storage, most 
of  which  are  end  users  (but 
also  manufacturers,  storage 
facilities 
transport 
and 
companies). 

Republic: 

Five 
Czech 
are 
companies 
manufacturers.  Up 
to  50 
involved in storage. Up to 10 
involved in distribution. Up to 
200  companies  are  using 
Employees 
explosives. 
directly 
with 
explosives 
between 
1000 and 1200. 

dealing 
are 

The  financial  and  economic 
costs  of 
the  action  are 
potentially  very  high  but 
impossible 
to  estimate  at 
this stage. Costs for a single 
vetting  procedure  vary  from 
to  2000  euro.  The 
20 
number  of  persons 
that 
could  be  affected  could  run 
into  hundreds  of  thousands 
when expanding it to sectors 
such  as  construction.  It  will 
therefore  be 
to 
establish  who  should  be 
vetted, who should carry out 
the  vetting  and  who  should 
pay  for  it.  The  economic 

important 

100 

criteria 
used 
for  vetting  and 
the 
to  whom 
information 
is 
disseminated 
to,  this  could 
affect 
data 
protection  and 
non-
discrimination 
principles. 

EN 

 
  
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
O 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

effects  are  likely  to  impact 
on  both  administrations  and 
industries  (which  may  have 
to  charge  it  through  to  their 
customers).  

consuming.  When  expanding 
such  a  measure  across  the 
Member  States,  it  is  important 
to  clarify  who  should  carry 
vetting  out  –  the  government 
or private sector? Who will pay 
for  it?  Will  the  manufacturers, 
distributors  etc  be  asked  to 
pay the costs for the vetting of 
their staff? 

, 

chain 

supply 

More importantly, in the last 10 
-  20  years  very  few  incidents 
have  happened  at  the  top  of 
(i.e. 
the 
production 
storage, 
distribution),  sectors  which 
already  have  many  security 
obligations 
in  place.  Most 
problems  occur  at  the  bottom 
levels  of 
industry  (e.g. 
quarries,  construction  sites) 
where  the  number  of  people 
is  enormous  and 
employed 
where staff turnovers are high. 
It may be practically unfeasible 
to  place  vetting  requirements 
on these kinds of companies. 

the 

etc 

Finally,  the  effect  of  vetting  in 
reducing 
is 
thefts 
questionable.  It  is  likely  that 
people  with  bad  intentions  will 
their 
make 
background is clear.  

sure 

that 

The scoring is low as a vetting 
system  covering  so  many 
levels  /  types  of  employment 
has a high potential for flaws 

EN 

101 

EN 

 
  
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
O 

S1  S2  S3  S4  S5  S6  Need 

to 

Objective 7: Improve the security 
of transport of explosives 

All  EX/II  and  EX/III  vehicles 
carrying  explosives  should  be 
equipped  with  certain  security 
enhancement solutions 

These security solutions include: 

18 

Commissi
on/ MS 

in 

their  security 

Thefts  of  such  vehicles  have 
the  past  and 
occurred 
increasing 
is 
therefore  a  sensible  option, 
especially  to  ensure  a  similar 
level  of  security  across  the 
EU. 

of 

also 

that 
Various  manufacturers 
are 
for 
responsible 
transporting  explosives  have 
pointed  out  however  that  the 
list 
not 
solutions 
exhaustive  and  does  not 
necessarily  include  the  most 
suitable  measures.  Some 
quoted for  example the use of 
camera  surveillance  on 
the 
vehicles. 

is 

A  number  of  actors  also 
questioned 
the  benefits  of 
remote  immobilisation,  as  this 
was  considered  a  potentially 
option  without 
dangerous 
ensuring  that  the  vehicle  in  a 
relatively ‘safe’ area. 

that 

systems), 

be  fitted  with  24  hour,  remote 
monitoring  systems  (e.g.  GPS 
based 
are 
monitored  by  an  appropriately 
resourced  monitoring  station. 
systems 
The 
Monitoring 
the 
(including 
Station)  must  reliably  enable 
where technically possible: 

Monitoring 

Vehicle location to be identified 

Alarm  activation 
is 
moved from specified location at 
certain times 

if  vehicle 

if  specified 
Alarm  activation 
compartments  are  opened  at 
certain 
at 
unauthorised locations. 

and/or 

times 

A  duress  and/or  a  panic  alarm 
facility. 

be  capable  of  immobilising  the 
engine  remotely 
if  safe  and 
applicable  subject  to  the  Vienna 
Convention 

EN 

2 

1 

2 

1 

50 

The  number  of  vehicles  in 
use  is  relatively  low  (40  in 
Sweden, 
in  Czech 
Republic,  two  countries  that 
together  have  an  important 
share  in  the  EU  explosives 
market).  The  vehicles  are 
used 
frequently, 
totalling  around  4,000  trips 
annually. 

very 

Most  Member  States  have 
security 
already 
various 
in 
enhancement  solutions 
place,  many  including  the 
ones  proposed  in  the  Action 
Plan. 

Adding  more 
solutions 
to 
(which  are  estimated 
amount  to  a  maximum  of 
2,000  euro  per  vehicle) 
low  cost, 
would 
especially 
the 
vehicles  are  already  very 
expensive. 

imply  a 

because 

that 

When  estimating 
the 
average  number  of  vehicles 
is  30  per  country  and  that 
they are used in 15 Member 
States,  the  total  costs  for 
improving 
security 
their 
would  be  around  900,000 
euro. 

102 

change 
EU 
legislation 

Possibly, if 
there  is  a 
need 
to 
integrate 
these 
requireme
nts 
transport 
related 
legislation. 

in 

on 

Effects 
fundamental 
rights 

Environment
al effects 

No 

No 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
O 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

fitted  with  an  anti 

be 
system.  

theft 

have 
compartments for explosives 

sufficiently 

secure 

fitted  with  a  means  of 

be 
communication 

have  a 
recognised  marking 
affixed to the roof of the vehicle, 
and 
a 
to 
description. 

specified 

size 

Objective  8:  Reduce  the  supply 
and  quality  of  information  on 
illicitly  manufacture 
how 
explosives 

to 

Limit the spread of bomb-making 
experience over the Internet 

Part  of 
41 

Non-legislative  option  including 
ISP, 
cooperation 
international 
and 
education initiatives. 

with 
bodies 

information 

Limiting  the  spread  of  bomb-
making 
and 
experience  is  very  difficult.  It 
would  however  be  a  proactive 
and  positive  measure 
to 
reduce the use of IEDs. 

The  measure  would  entail 
cooperation  with 
intensive 
providers. 
example, 
For 
YouTube  removes  up  to  50 
suspicious  video  messages 
per  day.  If  they  would  assist 
enforcement bodies identifying 
such  messages 
who  put 
this  would  strongly 
forward 
favour 
identification  of 
the 
distributors. 

costs 

financial 

The 
for 
cooperating  would  be  low, 
communication, 
including 
coordination,  reporting  and 
some  form  of  campaigns.  It 
is not possible to provide an 
estimate  as  the  action  as  it 
stands is rather vague. 

3 

2 

3 

2 

No 

No 

Possibly, if the 
cooperation 
the 
includes 
provision 
of 
personal  data, 
thus  affecting 
data protection 
principles. 

EN 

103 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
O 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

Detection Measures 

Objective  3: 
exchange of information 

Improving 

the 

Create  a  database  containing 
the  specifications  of  explosives 
produced within the EU  

32 

Commissi
on/ MS 

The  database(s)  would  target 
specifications 
explosives 
forensic 
by 
needed 
community  and  by  the  experts 
on detection. 

of 
the 

The  collection  of  data  on 
produced 
commercially 
explosives  could  be  a  helpful 
exercise.  It  should  also  be 
considered  whether  military 
explosives should be included. 
There may however be issues 
of  commercial  confidentiality 
issues, 
as  manufacturers 
could  be  reluctant  to  share  a 
high  extent  of  detail  on  their 
the 
(perhaps 
products 
necessary 
for 
forensics  and  detection,  but 
this  could  make  the  database 
less useful). 

just 
information 

Low  cost 
to  set  up  and 
maintain  a  database.  Some 
inputs from companies as to 
the  specifications  of 
their 
explosives, which would also 
be minimal. 

Set-up  and  organisation: 
50,000 
(database, 
euro 
virtual access, security) 

Internal  staffing:  0.5  FTE, 
totalling 25,000 euro 

Inputs:  average  5  days  per 
Member State per year at an 
average  fee  of  400  euro, 
totalling  54,000  euro  per 
year 

Outputs: 
reporting, 
(e.g. 
analysis) 4 summary reports 
of  5,000  euro, 
totalling 
20,000 euro. 

Total:  149,000  for  the  first 
year,  99,000  euro  for  the 
following years. 

Potentially  medium  financial 
and  economic  costs 
for 
manufacturers  to  update  the 
information  and  commercial 

104 

EN 

2 

2 

1 

No 

No 

No 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
on 

Effects 
fundamental 
rights 

Environment
al effects 

No 

No 

change 
EU 
legislation 

Possibly, 
EU 
legislation 
might  be 
required 

Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
O 

confidentiality risks. 

S1  S2  S3  S4  S5  S6  Need 

to 

2 

2 

2 

Objective  4:  Establish  EU-wide 
certification,  testing  and  trialling 
schemes 

Create 
certification 
detection solutions 

a  European  wide 
for 
scheme 

26 

Commissi
on/ MS 

At  present,  some  certification 
takes  place,  following  testing, 
at  the  level  of  the  individual 
Member  States,  particularly  in 
the  aviation  sector,  whilst 
other  countries  do  not  have 
in 
certification 
place. 

procedures 

would 

EU-wide 

An 
certification 
scheme 
enable 
equipment 
detection 
companies  to  access  the  EU 
market as a whole as opposed 
to  having  to  approach  every 
single  country.  This  would  in 
principle be beneficial in terms 
of  creating  economies  of 
scale, 
market 
single 
integration  and  resolve  delays 
and 
between 
obtaining 
well-functioning 
equipment.  

ordering 

Similar  to  the  concerns  raised 
under  action  25,  a  scheme 
would  only  work  if  the  overall 
detection 
performance 
material was good.  

of 

Other options than certification 
might be available. It would be 
important  to  learn  from  the 
to 
lessons  with 

regard 

for 

security 
in 
Investment 
related  capital 
items  at 
airports (in 18 MS) has risen 
significantly 
the 
responding  airports  during 
2000  and  2002;  rising  from 
to  €179m.  70%  of 
€32m 
investments  made  by 
the 
airports  in  2002  were  for 
equipment 
related 
acquisitions  (i.e.  EDS,  x-
biometric 
rays, 
scanners, 
The 
remaining  30%  was  mainly 
for 
related 
terminal 
redevelopments. 

CCTV, 

etc). 

Medium  set-up  costs 
to 
create  the  scheme  in  terms 
of  administrative  expenses, 
human resources and expert 
inputs. 

for 

Cost-efficiencies  once 
the 
system  will  certify  detection 
all  EU27. 
solution 
Reduced 
administrative 
costs  for  Member  States  as 
these  do  no  longer  have  to 
national 
go 
certification 
procedures, 
reduced costs for companies 
as  these  do  not  have  to 
apply  for  a  certificate  in  27 

through 

EN 

105 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

detection standards in aviation 
security. 

different countries. 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

G
O 

2 

2 

2 

No 

No 

costs 

financial 

The 
for 
creating  a  scheme  are 
to  be  medium. 
estimated 
be 
it  would 
However, 
essential 
that 
to  ensure 
projects have a strong focus 
on development (rather than 
on research only) in order to 
develop  new  products  for 
Positive 
the 
economic  effects 
the 
in 
longer  term  as  the  scheme 
would  reduce  administrative 
and production costs. 

market. 

could 

innovations 

As  for  action  26,  testing  is  at 
present  mainly  undertaken  by 
the  individual  Member  States, 
while  other  countries  do  not 
have  sufficient  resources  to 
launch 
testing 
their  own 
schemes. An EU-wide scheme 
would  therefore  be  beneficial, 
as Member States could share 
testing  data  and  pool  testing 
costs.  This 
offset 
development  costs  and  help 
stimulate 
and 
improvement, thus contributing 
detection 
increased 
to 
increased 
probability 
and 
prevention  and 
intervention 
opportunities.  In  some  sectors 
requiring 
public 
authorities  are  best  placed  to 
undertake  testing  and  trialling, 
as  they  have  easier  access  to 
explosives. 
be 
important  to  learn  from  other 
the  area  of 
in 
cooperation 
testing  (e.g.  some  progress 
has been made in the aviation 
sector). 

It  would 

detection, 

Create  a  European  wide  testing 
scheme for detection solutions 

27 

Commissi
on/ MS 

Under 
relevant 
the  scheme 
authorities  and  institutes  would 
be able to exchange test results. 

Create a European wide trialling 
scheme for detection solutions 

28 

Commissi
on/ MS 

Such  a  system  should  be 
supported by an EU programme 
and  should  allow  for  conducting 
performance trials under realistic 

EN 

106 

to 

The  benefits  of  the  action  are 
similar 
those  described 
under  actions  26  and  27.  EU 
trialling  would  enable 
wide 
Member  States 
share 
information  and  data  and 
would 
the  overall 
effectiveness  and  quality  of 

improve 

to 

2 

2 

2 

No 

No 

costs 

financial 

for 
The 
creating  a  scheme  are 
estimated 
to  be  medium. 
Some  costs  could  be  offset 
by the manufacturers. In the 
longer  term,  the  economic 
effect would be positive as it 
would  reduce  administrative 

Possibly, 
some 
environment
al  costs  for 
transport 
and handling 
of 
explosives  / 
chemicals 

Yes, 
environment
al  costs  due 
to  the  need 
for  specific 
laboratories 
and  facilities 
trial 
to 

EN 

 
  
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
O 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

conditions  in  same  or  similar 
scenarios. 

Preparedness  and 
measures 

response 

of 

However, 

the 
detection. 
detection 
performance 
equipment  is  difficult  to  trial 
and  measure  in  all  contexts 
(e.g. 
outdoor 
events).  

large-scale 

and development costs 

equipment 
under 
different 
conditions 

Objective  2:Develop 
preparedness  and 
measures 
using explosives 

for 

terrorist 

specific 
response 
threats 

Low  cost  related  to  liaison 
between  authorities  and 
providers.  Significant  costs 
could 
the 
application of this possibility. 

arise 

from 

1 

1 

1 

1 

Possibly, if 
EU  wide 
regulation
s 
were 
introduced 

No 

the 
Possibly, 
of 
respect 
and 
private 
family 
life 
which  includes 
communicatio
ns. 

Create the possibility for relevant 
law  enforcement  authorities  to 
request  providers  to  shut  down 
mobile  phone  antennas  in  the 
case  of  a  threat  of  a  terrorist 
attack 

In  a  situation  where  there  are 
reasons  to  believe  that  mobile 
phones  will  be  used  as  firing 
switches,  the  responsible  law 
enforcement  authorities  should 
be  able  to  request  providers  to 
shut down relevant antennas. 

practices 

Relevant experiences, skills and 
best 
be 
exchanged  among  the  Member 
States 
the  EOD-Units 
via 
network in this area. 

should 

44 and 
46 

MS/(Com
mission) 

important 

It  would  be 
for 
national  authorities  should  to 
first  liaise  with  their  network 
providers  to  agree  on  specific 
plans. Shutting down networks 
may  have  serious  collateral 
effects. 

the  world  e.g. 

Mobile  phones  have  been 
used  as  firing  switches  in  two 
ways.  The  Madrid  Cell  did  not 
utilise  the  network,  but  the 
time alert system on the phone 
itself.  However,  other  groups 
across 
in 
Chechnya,  South  Africa,  Iraq 
Ireland  have 
and  Northern 
sought 
IEDs  by 
initiate 
dialling a mobile phone that in 
turn  would set off a detonator. 
Counter-measures 
involving 
phone  networks  are  highly 
complex  and 
In 
order  to  function  effectively, 
measures  must  be  developed 

technical. 

to 

EN 

107 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
O 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

in  place  with 

and  put 
the 
network  providers  as  pre-
planned 
contingency 
measures.  

EN 

108 

EN 

 
  
 
Policy option 4 – maximum option 

Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
0 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

Prevention measures 

2: 

Improve 

Objective 
regulation 
precursors  available  on 
market 

the 
explosives 
the 

of 

for 

Introduce  a  system 
the 
recording  of  the  identity  of  the 
buyer  of  precursors  above 
and/or 
certain 
quantities 
concentrations.  The 
records 
should  be  available  to  the  law 
on 
enforcement 
request  or  provided 
the 
national  contact  point  in  case  of 
suspicious 
transactions.  All 
relevant  data  protection  rules 
should apply. 

authorities 
to 

The  relevant  quantities  and/or 
concentrations  would  be  set 
based  on 
the 
Standing Committee of Experts. 

the  work  of 

7 

MS/ 
Commissi
on 

The awareness of staff in such 
businesses is critical and there 
have  been  a  number  of 
instances in different countries 
where  public  and  business 
awareness  has  been  decisive 
in  alerting  the  authorities  to  a 
potential  conspiracy  to  cause 
an  explosion  by  a 
terrorist 
group.  The  introduction  of  a 
system to record the identity of 
the  buyer  might  therefore  not 
only  assist  in  the  detection  of 
purchases  after  an  incident, 
but  also  to  make  sellers  more 
alert. The recording could also 
act as a deterrent. 

The  financial  and  economic 
costs  of  developing  such  a 
recording  system  may  be 
high,  as  every  seller  would 
have  to  invest  some  time  in 
record-keeping. Whilst on an 
individual  level  this  is  minor, 
the  number  of  sellers 
is 
enormous  across  the  EU. 
There  are  some  potential 
fundamental rights issues as 
it could affect data protection 
however 
- 
principles 
processing  of  personal  data 
would  always  have  to  take 
in  accordance  with 
place 
existing 
protection 
legislation. 

data 

1 

1 

1 

1 

No 

No 

Yes, 
depending  on 
the  use  of  the 
information 
this 
recorded 
could 
affect 
data protection 
principles. 

8 

A  European  minimum  standard 
and  industrial  guidance  by  way 
of  an  appropriate  code  should 
be  defined 
the 
security of storage of explosives 
precursors  

concerning 

It  should  not  be  in  conflict  with 
other Regulations. 

MS/ 
Commissi
on 

While  standards  and  codes  in 
the  storage  of  explosives 
indeed 
precursors  would 
increase  security,  the  overall 
impact  and  the  feasibility  of 
their 
is 
questionable. 

implementation 

It  is  important,  first,  to  define 
what  is  meant  by  ‘storage’, 

The  costs  for  implementing 
European 
minimum 
standards  would  be  high. 
Effective  enforcement  would 
be  extremely  costly.  Whilst 
authorities 
large 
industries  in  the  wealthier 
Member  States  might  be 
such 
able 
smaller 
standards, 

introduce 

and 

to 

EN 

109 

1 

1 

1 

1 

No 

Possibly, if 
a  decision 
was  taken 
to  make 
the 
standards 
legally 
binding 
across  the 
EU. 

Possibly, 
some 
environment
al  costs  for 
additional 
security 
measures 
for  storage 
(e.g. 
fencing). 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
0 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

companies  and  precursor 
users may have the financial 
suitable 
resources 
or 
to 
infrastructure  available 
achieve  such  a 
level  of 
security. 

It 

farms? 

which could potentially cover a 
huge  area,  from  farmlands  to 
shop storage spaces. How can 
standards  or  a  code  of 
conduct be developed for such 
a  wide  variety  of  actors, 
especially for small users such 
is  worthwhile 
as 
noting  that  small-scale  actors 
target  of 
are  a  potential 
terrorists: 
liters  of 
the  400 
perioxide that was used for the 
failed 
21/7 
attempts 
London) 
in 
constituted  half  of  what  was 
in 
available 
in 
the  shops 
England. 
It  was  all  bought 
from 3-4 retailers. 

attacks 

(the 

the 

To  date,  most  explosive 
precursors  have  been  legally 
terrorists.  By 
purchased  by 
increasing 
security 
standards  of  storage  places 
and  placing 
restrictions  or 
bans  on  transactions,  there  is 
a  possibility  that  determined 
individuals  or  groups  would 
seek  to  obtain  such  materials 
from 
‘black  market’ 
sources.  

illegal 

Finally,  it  would  be  important 
to  clarify  whether  any  such 
code  would  be  voluntary  or 
statutory, 
imposed  by  EU 
legislation  or  by  national 
legislation? 

Objective  3:  Improve  the  control 
involving 
over 

transactions 

EN 

110 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
0 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

precursors 

Establish  a  system  of  reporting 
suspicious transactions.  

5 

MS/ 
Commissi
on 

Depending  on  the  substance, 
certain  concentrations  and/or 
quantities  should  be  subject  to 
transaction restrictions. 

could 
It  would 

be 
The  measure 
beneficial. 
be 
important  to  establish  a  clear 
definition 
‘suspicious 
of 
transactions’.  Several  existing 
industrial 
national 
and 
definitions  can  be  used  as  an 
example (e.g. the guidelines of 
Industries 
the 
Chemical 
Association  and 
the  Know 
Your Customer campaign).  

In  the  UK,  the  benefits  of  a 
system  can  be  illustrated  by 
the 
case  of  Mohammed 
Sidique  Khan  and  his  fellow 
(2005)  bombers,  who 
7/7 
purchased 
significant 
a 
quantity  of  Peroxide  and 
Acetone  precursors 
the 
for 
their  TATP 
construction  of 
rucksack  bombs,  which  they 
later  used  in  attacks  on  the 
London  Underground  and  a 
bus, 
Intelligence  & 
Security  Committee  Cm  6785 
2006). 

(see 

The  system  will  require  the 
establishment 
and 
enforcement 
/  policing  of 
certain standards, which could 
be  maintained  at  an  overall 
high  level  across  the  EU.  The 
system  could  for  example  a) 
follow  the  concept  used  to 
financial 
terrorist 
detect 
transactions 
all 
transactions  above  a  certain 

i.e. 

3 

3 

3 

3 

No 

No 

Yes, 
depending  on 
the  extent  and 
the  use  of  the 
information 
this 
recorded 
could 
affect 
data protection 
- 
principles 
however 
all 
processing  of 
personal  data 
would  need  to 
take  place  in 
accordance 
existing 
with 
data protection 
legislation. 

The  estimated  costs  of  a 
reporting  system  can  vary 
greatly.  Some  start-up  costs 
are  involved  to  set  up  the 
authority to whom producers 
and  sellers  should  report  to, 
including  equipment  and 
training of staff. 

The  costs  are  high  in  case 
the  system  would  look  like 
option  a)  mentioned  in  the 
assessment  of  benefits.  The 
obligation  to  report  on  every 
transaction  going  beyond  a 
certain  threshold  will  put  a 
high  strain  on  traders  (in 
terms  of  human  resources 
needed for reporting) but will 
most  of  all  entail  very  high 
administrative costs to check 
all transactions. 

to 

In  addition, 

The  costs  are  low  when  the 
decision 
report  on  a 
certain  transaction  is  left  to 
the  trader  (see  option  b),  as 
it  will  require  less  time  of 
those  that  are  selling  the 
products. 
the 
administrative costs will also 
the 
be 
number 
transactions 
reported is likely to be much 
lower. 
this  case,  as 
calculated  under  action  1 
above,  the  system  will  cost 
around  890,000  euro  in  the 
first  year  and  1,350,000  in 

reasonable 
of 

as 

In 

EN 

111 

EN 

 
  
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
0 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

the following years. 

The 
of 
introduction 
transaction  restrictions  will 
also  have  an  economic 
impact on the retail sector.  

quantity  /  concentration  have 
to  be  reported,  then  analysed 
and  assessed.  Alternatively,  it 
‘front-loaded’, 
could  b)  be 
relying  upon 
to 
trader 
make  the  decision  as  to  what 
is  suspicious  or  not.  More 
research  would  be  needed  to 
fully  explore  the  viability  of 
these two options. 

the 

The  system  should  not  strictly 
transaction 
be  based  on 
restrictions  but  also  on  the 
purchase  of  combinations  of 
substances 
are 
suspicious.  It  will  be  important 
to  combine  the  system  with 
awareness-raising 
(e.g. 
actions 1-3). 

which 

concerning 
to 
authority 

A  binding  system  should  be 
the 
created 
relevant 
notification 
any 
national 
of 
transactions 
the 
involving 
products on the list which can be 
considered suspicious 

the 

6 

MS/ 
Commissi
on 

A  “code  of  conduct”,  similar  to 
the EC code for drug precursors, 
should 
for 
industry and retailers, identifying 
the  behaviours  which  may  give 
rise to suspicion. 

developed, 

be 

in 

Most  of 
the  benefits  and 
disadvantages  of  the  system 
itself  are  discussed  under 
action  7  above.  As  mentioned 
earlier,  the  system  could  be 
advantageous 
alerting 
Member  States  and  their  law 
enforcement  authorities  to  the 
purchase 
potentially 
of 
dangerous  precursors  utilized 
in  the  construction  of  ‘home-
made’  High  Explosives  (HE). 
However,  the  cases  of  the 
extreme  right  wing  ‘lone-wolf’ 
terrorists,  David  Copeland  in 
the  UK  and  Eric  Rudolph  in 
the  USA  during 
later 
1990’s,  must  be  recalled.  The 
former  used  black  powder, 
emptying 
obtained 
by 
legally 
fireworks 

that  were 

the 

2 

2 

2 

2 

No 

Yes, 
depending  on 
the  extent  and 
the  use  of  the 
information 
this 
recorded 
could 
affect 
data protection 
principles. 

if 

Yes, 
there 
would  be 
regulation 
making 
the 
notification 
procedure
s 
binding 
across  the 
EU. 

legally 

As  mentioned  under  action 
5,  the  costs  of  a  system 
could range from low to high 
depending  on  the  reporting 
requirements  that  would  be 
put 
in  place.  A  binding 
system  would  automatically 
entail a relatively higher cost 
take 
as  one  has 
into 
additional 
account 
administrative 
of 
enforcement (e.g. controlling 
whether  all  producers  and 
traders 
effectively 
reporting  correctly,  fining  or 
prosecuting  those  that  are 
not, etc). 

costs 

are 

the 

to 

EN 

112 

EN 

 
  
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
0 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

the 

obtained  and  freely  available, 
latter  constructed 
while 
home made ‘pipe bombs’ from 
Low  Explosive  (LE)  powder. 
Both men were responsible for 
a number of fatalities (Kushner 
2003). 

However, the establishment of 
a binding system is likely to be 
less  favourable  and  can  even 
be counter-productive. It would 
have  a  ‘negative’  connotation 
as it would imply that those not 
reporting  could  potentially  be 
prosecuted.  A  system  based 
on voluntary inputs and coders 
would  therefore  create  more 
‘goodwill’ than a system which 
is imposed on traders. 

Low 
some 
costs,  with 
financial impacts on retailers 
but likely to be minor. 

1 

1 

1 

1 

Yes 

No 

Introduce  a  complete  ban  on 
selling precursors to minors. 

10 

MS/ 
Commissi
on 

to 

low 

impact 

The  action  may  prove  very 
difficult  to  enforce  and  have 
relatively 
(the 
precursors  will  be  purchased 
by  adult  terrorists).  Equivalent 
great  efforts  to  prevent  the 
sale  of  fireworks,  alcohol  and 
juveniles  and 
cigarettes 
minors in most Member States 
testify  the  challenges  faced. 
Finally,  bearing  in  mind  that  a 
major  ingredient  of  the  TATP 
the  21/7 
bombs  used 
attempted  attacks  in  London 
was 
flour”,  how 
comprehensive  could  such  a 
lost of precursors be? 

“Chappati 

in 

Objective  4:  Improve  the  control 
over  explosives available  on  the 

EN 

113 

Some 
environment
al 
benefits 
especially  in 
terms 
of 
safety. 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
0 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

market and pyrotechnic articles 

Harmonise  EU  requirements  for 
the  licensing  and  handling  of 
large  amounts  of  pyrotechnic 
articles 

43 

Commissi
on/ MS 

handle 

towards 
to 

lack  of  any  harmonised 
The 
licensing 
approach 
schemes 
large 
quantities  of  pyrotechnic  articles 
to 
means 
handle  such  materials  without 
long 
regulatory  oversight  as 
storage 
transport 
and 
requirements  are  met.  Such  a 
security gap should be closed. 

is  possible 

that 

it 

3 

2 

3 

2 

2 

Yes 

No 

Some 
environment
al 
benefits 
especially  in 
of 
terms 
safety. 

High  cost  for  Member  State 
authorities  and  companies, 
relating  to  the  development 
(or  elaboration)  of  licensing 
control, 
systems, 
compliance, 
enforcement, 
administrative 
procedures 
etc. 

Further licensing requirements 
for  pyrotechnic  articles  would 
have  a  positive  effect  given 
that  the  use  of  these  articles 
for the development of an IED 
constitutes a real risk. It would 
increase 
explosives 
IED 
security,  particularly  when 
David 
considering 
Copeland 
the 
lethal  homemade  IEDs  that 
killed  six  people  by  utilising 
black  powder  obtained  from 
fireworks  (see  also  measure 
7). 

that 
constructed 

It 

is  no 

In the UK the fireworks market 
was  deregulated  around  10 
years  ago. 
longer 
necessary  to  have  a  license 
for  producing  and  handling 
pyrotechnic articles. Their size 
has  increased,  making  them 
similar to explosive devices. 

Detection Measures 

Objective 
2: 
minimum detection standards 

Developing 

Develop  minimum 
standards  

detection 

25 

Commissi
on/ MS 

These  standards  should  be 
updated as technology evolves 

Minimum  detection  standards 
would  help  to  increase  the 
overall  quality  of  detection 
systems,  thus  increasing  the 
probability of detection as well 
as  prevention  and  intervention 
opportunities. 
It  would  be 
important  to  learn  from  the 

can 

The  process  of  developing 
detection 
minimum 
standards 
be 
undertaken  at  a  medium 
cost.  Some  administrative 
costs  to  cover  negotiation 
and  publication,  as  well  as 
some  expert  inputs  to  steer 

1 

1 

1 

Yes 

No 

No 

EN 

114 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
0 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

the work. 

the 

regulation 

experiences 
field  of 
in 
aviation  security,  where  a 
framework 
(No 
2320/2002),  adopted  in  2003, 
made  the  security  measures 
set  out  by  the  European  Civil 
Aviation  Conference  (ECAC) 
compulsory within the EU. The 
Annexes to the Regulation set 
out  common  basic  standards 
for  aviation  security, 
laying 
down performance criteria and 
acceptance  tests  for  detection 
equipment.  The 
standards 
also  relate  to  what  screening 
and  other  control  processes 
should  be  used,  which  items 
should  be  checked  and  skills 
requirements for staff. 

Some 
account are: 

issues 

to 

take 

into 

‘vague’, 

Setting 
wide 
standards  will  not  make  a  lot 
of  difference  as  they  could  be 
interpreted  in  different  ways. 
Setting very precise standards 
would  not  leave  much  space 
for  flexibility  and  take  account 
of different contexts. 

Standardisation may be useful 
solutions 
current 
if  most 
worked  very  well,  but  often 
equipment  does  not  perform 
as  it  should.  The  drastically 
increased 
for 
detection since 9/11 has led to 
production 
detection 
investing 
companies 

demand 

not 

EN 

115 

EN 

 
  
 
Measure / action 

Rec. 
no 

Competen
t body 

Assessment of benefits 

Financial 
effects 

and 

economic 

G
0 

S1  S2  S3  S4  S5  S6  Need 

to 

change 
EU 
legislation 

on 

Effects 
fundamental 
rights 

Environment
al effects 

sufficiently  in  innovation  but 
focusing  on  fast  production  / 
delivery instead. 

types  of 
In 

The  sector  may  benefit  from 
other 
(additional) 
the  Cosmetic 
measures. 
industry, 
example, 
for 
companies  use  a  product 
information  sheet,  which  can 
be  accessed  by  authorities.  If 
the  product  does  not  perform 
in  line  with  the  indications  on 
the  sheet,  its  sales  can  be 
suspended.  Good  practices 
could 
the 
development of standards. 

inform 

also 

EN 

116 

EN 

 
  
 
ANNEX 2 – LIST OF ESETF RECOMMENDATIONS 

Number  Recommendation 

The public authorities should provide security information to the entire supply chain, from 
manufacturers  to  the  retailers,  first  responders  (police,  fire-departments,  bomb-squads) 
and educational establishments to focus attention on products of concern. 

Simple  means  should  exist  for  anyone  within  the  supply  chain  to  alert  the  relevant 
national authority if they see a transaction or theft which they suspect to have been made 
with  the  intention  of  illegally  fabricating  explosives.  Each  party  within  the  supply  chain 
must  inform  the  relevant  national  authority  in  the  event  of  any  theft  or  loss  of  the 
aforementioned products at concentrations in excess of those identified in Annex 2 (of the 
ESETF  report).  The  relevant  national  authorities  are  required  to  inform  their  national 
central agency which is responsible for gathering this information. 

Campaigns could be conducted to raise staff-awareness of the threat all along the supply 
chain amongst manufacturers, formulators, distributors and retailers. 

A  system  should  be  established  concerning  the  regulation  of  explosives  precursors 
available on the market. 

Development  of  suitable  additives  and  promotion  of  the  use  of  these  additives  to 
precursors in order to prevent their use in explosives, when it is technically possible. 

Restrictions on concentration concerning the sale of certain precursors to end-users. 

A complete ban on concentrated strong acids to EU consumer markets (non-professional 
markets)  when  a  substitute  giving  an  equal  use  is  technically  possible:  sulphuric, 
hydrochloric and nitric acids in particular. 

Limiting the availability of pure nitromethane to the general public. It should be available 
to industrial customers via a suitable customer qualification scheme. 

Restrictions  on  access  of  the  general  public  to  unphlegmatized  sodium  chlorate  (weed 
killer). 

A  system  of  reporting  suspicious  transactions  should  be  established,  comparable  to 
existing systems for drugs precursors or suspicious financial transactions. Depending on 
the  substance,  certain  concentrations  and/or  quantities  must  be  subject  to  transaction 
restrictions. 

A  binding  system  should  be  created  concerning  the  notification  to  the  relevant  national 
authority  of  any  transactions  involving  the  products  on  the  list  which  can  be  considered 
suspicious. 

The sale of any product on the list, above the quantities and/or concentrations indicated, 
must  be  recorded,  including  recording  the  identity  of  the  buyer  to  be  proven  by  a 
nationally  accepted  means  of  identification.  The  records  must  be  available  to  the  law 
enforcement  authorities  on  request  or  provided  to  the  national  contact  point  in  case  of 
suspicious transactions. All relevant data protection rules should apply. 

A  European  minimum  standard  and  industrial  guidance  by  way  of  an  appropriate  code 
should be defined concerning the security of storage of explosives precursors on the list. 
It must not be in conflict with other Regulations. 

For each product on the list which is handled by the retail sector, all packaging must be 
labelled  with  a  code  specifying  that  the  purchase  of  this  substance  may  be  subject  to 
registration (subject to further verification). 

No substance on the list of explosives precursors should be sold to minors. 

All personnel employed in the manufacturing, storage, distribution and use of explosives 
should  be  vetted  (external  checks  by  relevant  national  authorities  under  applicable 
national regulations) and hold a formal authorisation to have access to explosives. 

EN 

117 

   EN 

 
Effective  Security  Plans/Security  Management  Systems  should  be  operational  at  all 
explosives facilities (manufacturing, storing, distributing and using). 

It  should  become  obligatory  for  the  relevant  national  authorities  to  keep  explosives 
manufacturers and distributors informed as to the regional threat at all times. Response 
plans should be developed tuned to the level of alert present. 

The  levels  of  necessary  access  prevention  and  detection  provisions  in  fixed  storage 
facilities  should  be  proportional  to  the  risk  and  should  be  subject  to  a  standard 
classification. 

Mobile  explosives  manufacturing  units  (MEMUs)  should  have  at  least  two  independent 
systems for recording the amount of explosives produced. 

Mobile  explosives  manufacturing  units  (MEMUs)  must  be  fitted  with  process  locks  to 
prevent unauthorised use. 

Loaded  mobile  explosives  manufacturing  units  (MEMUs)  should  be  parked  on  a  site 
which is guarded or monitored when they are not in use. 

All  EX/II  and  EX/III  vehicles  carrying  explosives  shall  be  equipped  with  the  security 
enhancement solutions identified below. 

Consideration  should  be  given  to  materials  that  are  classified  as  “desensitized 
explosives”. A review of the classification of these substances should be performed. 

Raw materials used in the manufacture of bulk explosives and finished product should be 
periodically accounted for and reconciled as approved by the National Authorities. 

Member States should have formal systems for authorising, regulating and licensing the 
manufacture,  storage,  sale,  use  and  possession  of  explosives  including  by  private 
persons. 

Identifying  and  tracing  of  explosives  should  be  implemented  in  accordance  with  the 
proposed  Directive  on  the  identification  and  traceability  of  explosives  for  civil  use 
(Traceability Directive). 

A government level working group should be created which would first discuss scenarios 
and then requirements for the scenarios. 

A matrix of what is desired and of what is possible today should be developed for each 
scenario. 

Minimum  detection  standards  should  be  determined  at  government/EU  legislative  level 
and updated as technology evolves. 

Create a European wide certification scheme. 

Create  a  European  wide  testing  scheme  and  a  system  where  relevant  authorities  and 
institutes could exchange the test results. 

Create  a  mechanism  supported  by  a  programme  within  the  EU,  where  performance  of 
trials under realistic conditions in same or similar scenarios would be possible. 

Assess the need of the certification, testing and trialling processes for standards. 

Assess and improve where necessary the situation as regards the availability of training 
data for manufacturers of detection solution and feedback. 

Given  the  threats  of  Improvised  Explosive  Devices  to  security  in  general  and  airport 
security  in  particular,  measures  aimed  at  improving  the  usage of  detection  technologies 
should be contemplated, in particular for hold luggage. Research in this area should be 
supported.  In  addition,  cargo  which  is  transported  on  a  passenger  plane  should  be 
subject to the same security procedures as hand and hold luggage. 

A database or databases containing the specifications of explosives produced within the 
EU could be created. 

Create an end-user focused handbook. 

EN 

118 

   EN 

 
Create a network of experts on the detection of explosives. 

A European Bomb Data System should be created and promoted at Europol and in the 
Member  States  in  order  to  provide  for  a  common  EU  instrument  enabling  authorised 
governmental  bodies  at  EU  and  Member  States  level  to  have  24/7  access  to  relevant 
information on incidents involving explosive devices. Europol should be urged to continue 
its  efforts  to  involve  Member  States  in  discussions  and  possible  decisions  on  a  future 
system. Possibilities for obtaining EU financing for the development of the database both 
at Europol and in the Member States must be thoroughly explored. 

At  least  all  operational  EOD  units  in  the  Member  States  should  have  access  to  the 
database. Other competent authorities in the Member States should also be given access 
in line with national law. 

Competent units or bodies of the Member States should be strongly obliged to provide all 
necessary information for inclusion in the database. 

An EU network of EOD-Units should be established. Possibilities to obtain EU funding for 
the establishment and to ensure continuity of the network should be explored. 

An Early Warning System (EWS) for explosives related incidents should be established, 
taking account of existing systems and experiences, including the G6 system. 

All  competent  authorities  in  the  Member  States,  including  all  operational  EOD  units, 
should have access to the EWS. 

Criminal sanctions should be harmonized for distributing bomb making experience across 
the  internet.  Non-legislative  options  to  deal  with  the  issue  should  also  be  investigated 
further. EU wide programmes on this topic would be beneficial. 

Security  staff  at  airports  should  be  provided  on  a  continuous  basis  with  up-to-date 
information on new terrorist modi operandi or other relevant threat information. 

In  addition  to  the  new  requirements  included  in  the  new  Directive  on  this  issue, 
harmonised EU requirements should also be applicable for licensing and handling of large 
amounts of pyrotechnic articles. 

If  there  are  reasons  to  believe  that  mobile  phones  will  be  used  as  firing  switches,  the 
responsible  law  enforcement  authorities  should  contact  providers  to  shut  down  relevant 
antennas. 

Further research is recommended in order to find technical solutions for Member States' 
authorities to jam mobile phone signals in critical areas. 

An  exchange  of  experiences,  skills  and  best  practices  should  take  place  through  the 
European EOD-units network. 

The research needs identified above should be taken into consideration by the European 
Commission when establishing the working programmes for security related research. 

Research  should  be  performed  to  find  inhibitors  which  could  be  added  to  precursors  to 
explosives to prevent them being used to manufacture explosive devices. 

Improve  the  aggregation  and  spread  of  research  results  both  at  EU  level  as  well  as  at 
national level across the EU Member States. 

The European Commission should regularly (every two years) organise an event on the 
security  of  explosives  covering  all  relevant  issues.  Such  an  event/conference  should 
continue involving top officials, both public and private sector's practitioners could share 
experience,  knowledge  and  best  practices.  It  could  be  accompanied  by  issue  specific 
workshops  and  seminars  and  supported  by  a  newsletter.  The  issues  covered  could  be 
policy, regulation, trade and research relevant. 

EN 

119 

   EN 

 
ANNEX 3 – SUMMARY ASSESSMENT TABLE 

Cost and predictability 
assessment 
Low, predictable: <500,000 euro 
Medium, predictable: >500,001 - 
<2,000,000 euro 
High, predictable: >2,000,000 euro 
Low, uncertain: Feasibility work 
needed, costs potentially low 
Medium, uncertain: Feasibility work 
needed 

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Objectives 

Options and actions 

OPTION 1 – STATUS QUO 

Horizontal measures 

Improve the exchange of timely 
information and best practice 

Europol and Eurojust 

Strengthen explosives related 
research 

Current FP7 research with regard to 
detection and public security (e.g. 
Security Research Call 1 of Dec 
2006) 

Prevention measures 

Improve the control over explosives 
available on the market and 
pyrotechnic articles 

Implementation of the Traceability 
Directive (action 22) 

Directive on explosives for civil use 

Reduce the supply and quality of 
information on how to illicitly 
manufacture explosives 

GO1 

SO1 

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e
f
f
e

v
n
E

n
o
i
t
p
o
d
e
r
r
e
f
e
r
P

SO3 

SO4 

SO5 

SO6 

2 

1 

2 

low 
predictable 

medium 

No new 
issues 

No new 
issues 

No new 
issues 

medium, 
predictable 

medium 

No new 
issues 

No new 
issues 

No new 
issues 

Assessed by 
way of a 
separate 
impact 
assessment 

No new 
issues 

No new 
issues 

No new 
issues 

EN 

120 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Harmonize criminal sanctions for 
distributing bomb-making experience 
over the Internet (action 41) 

Improve the security of transport 
of explosives 

ADR legislation and working group 
on transport 

Detection Measures 

EU legislation in the area of aviation 
security 

1 

1 

3 

1 

2 

1 

1 

1 

low, 
predictable 

No new 
issues 

No new 
issues 

No new 
issues 

Cannot be 
assessed at 
this time 

Cannot be 
assessed at 
this time 

No new 
issues 

No new 
issues 

No new 
issues 

No new 
issues 

No new 
issues 

No new 
issues 

2 

2 

EN 

121 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
OPTION 2 - MINIMUM OPTION 

Horizontal measures 

Improve the exchange of timely 
information and best practice 

39. and 40. Establish an Early 
Warning System 

50. Regularly organise an event on 
the security of explosives 

Develop threat assessments 

No rec number: Consider developing 
specialised threat assessments 

Strengthen explosives related 
research 

49. Improve the aggregation and 
spread of research results 

47. Perform further research on: 
 1 - IEDs 
 2 - Chemicals found at an 
investigation scene 
 3 - Detection of explosives and 
precursors 
 4 - Mobile explosives kits 

31. Perform further research 
concerning the detection of 
Improvised Explosive Devices at 
airports, in particular for hold luggage 

48. Perform further research to find 
inhibitors which could be added to 
precursors 

45. Support further research to find 
technical solutions to jam mobile 
phones 

Prevention measures 

Improve staff awareness and 
alerting concerning precursors 

1. Public authorities to provide 
security information to the entire 
precursor supply chain 

2. Simple means within supply chain 
to alert national authority 

3 

2 

1 

1 

2 

2 

2 

2 

2 

3 

2 

1 

1 

2 

2 

2 

2 

3 

1 

1 

1 

1 

1 

2 

2 

2 

3 

EN 

2 

1 

1 

2 

2 

2 

3 

1 

1 

1 

122 

3 

1 

1 

1 

1 

2 

3 

Medium, 
predictable 

Low, 
predictable 

Medium, 
uncertain 

Low, 
predictable 

High, 
predictable 

High, 
predictable 

High, 
predictable 

Low, 
predictable 

High, 
predictable 

Medium, 
predictable 

Medium 

Low 

No 

No 

No 

No 

No 

Possibly 

Yes 

yes 

Low 

No 

No 

No 

yes 

Low 

No 

No 

No 

yes 

Medium 

No 

No 

Yes 

yes 

Medium 

No 

No 

No 

yes 

Medium 

No 

No 

Yes 

yes 

Medium 

No 

Possibly 

Possibly 

yes 

High 

No 

No 

Possibly 

yes 

High 

No 

Possibly 

No 

yes 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
3 

3 

3 

3 

3 

Medium, 
uncertain 

High 

No 

Possibly 

Possibly 

yes 

3. Campaigns to raise staff-
awareness all along supply chain 

Improve the control over 
transactions involving precursors 

9. Assessing benefits of creating a 
scheme for each precursor handled 
by retail sector, under which all 
packaging would be labelled with a 
code specifying subject of 
registration 

Improve the control over 
explosives available on the market 
and pyrotechnic articels 

19. Launch debate on the need to 
review the classification of 
"desensitized" explosives 

Improve the security of explosive 
facilities 

12. and 14. Effective Security 
Plans/Security Management Systems 
at all facilities 

Detection Measures 

Establish scenario based 
approach to identifying work 
priorities 

23. Setup of a working group to 
develop scenarios and to identify 
technology requirements 

24. Create matrix of what is desired 
and currently possible in each 
scenario 

Developing minimum detection 
standards 

Part of 25 and 27: Develop 
mechanisms for the identification and 
dissemination of good practice in 
detection systems and use of 
detection equipment 

Improving the exchange of 
information 

0 

1 

1 

4 

4 

2 

2 

1 

2 

2 

2 

1 

2 

2 

1 

EN 

123 

Low, 
predictable 

Low 

Possibly 

No 

No 

Feasibility work 
should 
consider 
alternative 
means to 
achieve 
objective 

Low, 
predictable 

High, 
uncertain 

Low, 
predictable 

Low, 
predictable 

Low 

No 

No 

No 

yes 

High 

No 

No 

Possibly 

yes 

Low 

No 

No 

Possibly 

Yes 

Low 

No 

No 

No 

yes 

Low, 
predictable 

Low 

No 

No 

No 

Should be 
considered as 
possible 
alternative to 
minimum 
standards 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
42. Ensure that security staff are 
provided with up-to-date information 
on new terrorist modi operandi 

30. Assess and improve where 
necessary the situation as regards 
the availability of training data and 
other information/feedback for 
manufacturers of detection solutions 

33. Create an end-user focused 
handbook concerning detection 

34. Create a network of experts on 
the detection of explosives 

Establish EU-wide certification, 
testing and trialling schemes 

29. Assess the need for the 
development of standards 
concerning certification, testing and 
trialling processes. 

Improve the usage of detection 
technologies in specific locations 

31. Improve the use of detection 
technologies at airports, railway 
stations and other public facilities. 

Preparedness and response 
measures 

Improve the exchange of 
information and best-practices 
among relevant Member State 
authorities 

38. Establish a European EOD 
Network 

2 

3 

2 

2 

2 

1 

0 

2 

1 

3 

3 

Total score Objectives Option 2 

Average score Objectives Option 2 
(24 actions) 

47 

2,0 

30 

1,3 

14 

0,6 

3 

0,1 

EN 

3 

2 

2 

2 

2 

3 

35 

1,5 

2 

1 

1 

1 

Low, 
predictable 

Low, 
uncertain 

Low, 
predictable 

Low, 
predictable 

Low, 
predictable 

High 

No 

Possibly 

No 

yes 

Low 

No 

No 

No 

yes 

Low 

No 

No 

Possibly 

Feasibility work 
should 
consider 
alternative 
means to 
achieve 
dissemination 
objective 

Low 

No 

No 

Possibly 

yes 

Low 

No 

No 

No 

yes 

2 

Low, 
predictable 

Low 

No 

No 

No 

yes 

2 

31 

1,3 

3 

0,1 

124 

Medium, 
predictable 

Medium 

No 

No 

Possibly 

yes 

EU 
legislation 

Effects on 
FR 

Env 
effects 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Total score Cost and predictability 
asssessment 

Total score Dependance on other 
actors 

Low, predictable 

Medium, predictable 

High, predictable 

Low, uncertain 

Medium, uncertain 

High, uncertain 

Low 

Medium 

High 

13 

3 

4 

1 

2 

1 

13 

6 

5 

No 

13 

Possibl
y 

9 

Yes 

2 

57% 

13% 

No 

23 

No 

20 

17% 

Possibly 

Possibly 

1 

Yes 

0 

4 

Yes 

0 

4% 

9% 

4% 

46% 

21% 

18% 

EN 

125 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
OPTION 3 - INTERMEDIATE 
OPTION 

Horizontal Measures 

Improve the exchange of timely 
information and best practices 

35, 36 and 37. Create a European 
Bomb Database 

2 

Prevention Measures 

Improve the regulation of 
explosives precursors available on 
the market 

2 

1 

1 

Medium, 
predictable 

High 

Possibly 

No 

No 

yes 

4. The establishment of a system 
concerning the regulation of 
explosives precursors available on 
the market 

Improve the control over 
explosives available on the market 
and pyrotechnic articles 

21. Ensure that each Member States 
has formal systems for authorising, 
regulating and licensing the 
manufacture, storage, sale, use and 
possession of explosives including by 
private persons. 

Improve the security of explosives 
facilities 

13. Introduce an obligation for the 
relevant national authorities to keep 
explosives manufacturers and 
distributors informed as to the 
regional threat at all times 

20. Raw materials used in the 
manufacture of bulk explosives and 
finished product should be 
periodically accounted for and 
reconciled as approved by the 
National Authorities. 

15., 16., 17. Improve the security of 
Mobile Explosive Manufacturing 
Units (MEMUs) 

3 

2 

3 

3 

Low, 
predictable 

Low 

Possibly 

No 

Possibly 
positive 

yes, but impact 
and costs 
dependent 
upon the actual 
system. 
Feasibility work 
required 

2 

2 

1 

1 

1 

1 

1 

1 

1 

1 

1 

Medium, 
uncertain 

High 

Possibly 

No 

No 

yes, but 
feasibility work 
required 

Medium, 
uncertain 

Medium, 
uncertain 

Medium, 
predictable 

Medium 

No 

Possibly 

No 

yes 

High 

No 

No 

No 

yes, but 
feasibility work 
required 

Medium 

Possibly 

No 

No 

yes 

EN 

126 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Improve the security vetting of 
personnel 

11. All personnel employed in the 
manufacturing, storage, distribution 
and use of explosives should be 
vetted and hold a formal 
authorisation to have access to 
explosives. 

Improve the security of transport 
of explosives 

18. All EX/II and EX/III vehicles 
carrying explosives should be 
equipped with certain security 
enhancement solutions 
These security solutions include: 
1) be fitted with 24 hour 
2) be capable of immobilising the 
engine remotely if safe and 
applicable subje 

Reduce the supply and quality of 
information on how to illicitly 
manufacture explosives 

Part of 41: Limit the spread of bomb-
making experience over the internet 

Detection Measures 

Improving the exchange of 
information 

32. Create a database containing the 
specifications of explosives produced 
within the EU 

Establish EU-wide certification, 
testing and trialling schemes 

26. Create a European wide 
certification scheme for detection 
solutions 

1 

1 

2 

1 

3 

2 

3 

2 

2 

2 

1 

2 

2 

2 

EN 

127 

1 

High, 
uncertain 

High 

No 

Possibly 

No 

yes, but 
feasibility work 
required 

1 

Medium, 
predictable 

Medium 

Possibly 

No 

No 

yes 

Low, 
uncertain 

Medium, 
uncertain 

Medium, 
uncertain 

1 

2 

Medium 

No 

Possibly 

No 

yes 

Low 

No 

No 

No 

yes 

Low 

Possibly 

No 

No 

depends in part 
on results of 
recommendatio
n 29 to assess 
need for 
standards 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
27. Create a European wide testing 
scheme for detection solutions 

28. Create a European wide trialling 
scheme for detection solutions 

Preparedness and response 
measures 

Develop specific preparedness 
and response measures for 
terrorist threats using explosives 

44. and 46. Create the possibility for 
relevant law enforcement authorities 
to request providers to shut down 
mobile phone antennas in the case of 
a threat of a terrorist attack 

ADDITIONAL SCORE OPTION 3 

Average score Objectives Option 3 
(14 actions) 

Total score Cost and predictability 
asssessment 

Total score Dependance on other 
actors 

2 

2 

1 

14 

1,0 

2 

2 

2 

2 

1 

1 

25 

1,8 

11 

0,8 

6 

0,4 

1 

6 

0,4 

14 

1,0 

1 

0,1 

Low, predictable 

Medium, predictable 

High, predictable 

Low, uncertain 

Medium, uncertain 

High, uncertain 

TOTAL SCORE OPTION 3 
(including OPTION 2) 

72 

41 

20 

9 

EN 

Low 

Medium 

High 

49 

4 

45 

128 

Medium, 
uncertain 

Medium, 
uncertain 

Low 

No 

No 

Possibly 

Low 

No 

No 

Yes 

depends in part 
on results of 
recommendatio
n 29 to assess 
need for 
standards 

depends in part 
on results of 
recommendatio
n 29 to assess 
need for 
development of 
standards 

Low, 
uncertain 

Medium 

Possibly 

Possibly 

No 

yes 

EU 
legislation 

Effects on 
FR 

Env 
effects 

No 

7 

No 

10 

No 

11 

Possibly 

Possibly 

Possibly 

7 

Yes 

0 

4 

Yes 

0 

2 

Yes 

1 

1 

3 

0 

2 

7 

1 

5 

5 

4 

8% 

25% 

0% 

17% 

58% 

8% 

42% 

42% 

33% 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Average score Objectives Option 3 
including Option 2 (38 actions) 

Total score Cost and predictability 
asssessment 

Total score Dependance on other 
actors 

1,9 

1,1 

0,5 

0,2 

1,3 

0,1 

1,2 

Low, predictable 

Medium, predictable 

High, predictable 

Low, uncertain 

Medium, uncertain 

High, uncertain 

Low 

Medium 

High 

14 

6 

4 

3 

9 

2 

18 

11 

9 

35% 

15% 

10% 

8% 

23% 

5% 

45% 

28% 

23% 

EN 

129 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
OPTION 4 - MAXIMUM OPTION 

Prevention Measures 

Improve the regulation of 
explosives precursors available on 
the market 

7. Introduce a system for the 
recording of the identity of the buyer 
of precursors above certain 
quantities and/or concentrations. 

8. A European minimum standard 
and industrial guidance by way of an 
appropriate code concerning the 
security of storage of explosives 
precursors 

Improve the control over 
transactions involving precursors 

5. Establish a system of reporting 
suspicious transactions. 

6. A binding system concerning the 
notification to the relevant national 
authority of any transactions 
involving the products on the list 
which can be considered suspicious 

1 

1 

1 

1 

3 

2 

3 

2 

10. Introduce a complete ban on 
selling precursors to minors. 

1 

1 

1 

1 

3 

2 

1 

1 

1 

3 

2 

1 

High, 
uncertain 

High, 
uncertain 

High, 
uncertain 

High, 
uncertain 

Low, 
uncertain 

High 

No 

Yes 

No 

High 

Possibly 

No 

Possibly 

High 

No 

Yes 

No 

High 

Yes 

Yes 

No 

High 

Yes 

No 

Possibly 

Improve the control over 
explosives available on the market 
and pyrotechnic articles 

43. Harmonise EU requirements for 
the licensing and handling of large 
amounts of pyrotechnic articles 

Detection measures 

Developing minimum detection 
standards 

3 

2 

3 

2 

2 

High, 
uncertain 

High 

Yes 

No 

Possibly 
positive 

Feasibility work 
should be 
undertaken 

Feasibility work 
should be 
undertaken, 
likely to require 
Impact 
assessment 

Feasibility work 
should be 
undertaken 

Feasibility work 
should be 
undertaken 

yes, but 
feasibility work 
required to 
assess 
likelihood of 
enforcement 

Feasibility work 
should be 
undertaken, 
likely to require 
Impact 
assessment 

EN 

130 

EN 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
25. Develop minimum detection 
standards 

ADDITIONAL SCORE OPTION 4 

Average score Objectives Option 4 
(7 actions) 

Total score Cost assessment 

1 

12 

1,7 

10 

1,4 

11 

1,6 

10 

1,4 

1 

1 

0,1 

0 

0,0 

2 

0,3 

Low, predictable 

Medium, predictable 

High predictable 

Low, uncertain 

Medium, uncertain 

High, uncertain 

Low 

Medium 

High 

50 

4 

47 

Medium, 
uncertain 

Medium 

Yes 

No 

No 

Feasibility work 
should 
consider 
alternative 
means of 
improving 
quality of 
detection 
equipment. 

EU 
legislation 

Effects on 
FR 

Env 
effects 

No 

2 

No 

4 

No 

4 

Possibly 

Possibly 

Possibly 

1 

Yes 

4 

0 

Yes 

3 

3 

Yes 

0 

0 

0 

0 

1 

1 

5 

1 

1 

6 

14 

6 

4 

4 

10 

7 

19 

12 

15 

0% 

0% 

0% 

14% 

14% 

71% 

14% 

14% 

86% 

30% 

13% 

9% 

9% 

21% 

15% 

40% 

26% 

32% 

EN 

Total score Dependence on other 
actors 

TOTAL SCORE OPTION 4 
(including OPTION 2 and 3) 

Average score Objectives Option 3 
including Options 2 and 3 (45 
actions) 

Total score Cost and predictability 
assessment 

Total score Dependence on other 
actors 

EN 

84 

51 

31 

19 

1,9 

1,1 

0,7 

0,4 

1,1 

0,1 

1,0 

Low, predictable 

Medium, predictable 

High, predictable 

Low, uncertain 

Medium, uncertain 

High, uncertain 

Low 

Medium 

High 

131 

 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EN 

132 

EN