Out of date flares are being dumped in harbours, in the sea and outside coastguard stations, according to one coastguard I've recently spoken to.
This is illegal and a serious safety hazard which is causing concern among some of the folk who have to deal with it.
Part of the reason is that there is now just one disposal point on the west coast of mainland Scotland, and it is among the most popular sailing destinations in the UK.
So, what changed?
In 2005 new carriage and storage regulations for explosives came into force, with two key effects.
1. Until 2005 Coastguards (MCA) had Crown Exemption from previous explosive acts, allowing it to store out of date flares. Now it doesn't.
2. The routine collection service, from MCA sites and other locations, by Explosive Ordnance Disposal Teams was withdrawn by the MoD. Interim arrangements were set up between the MoD and Coastguard stations, but these ran out last March.
So from 1st April a new system came into force for disposing of Time Expired Pyrotechnics (TEPs) as these are formally known..
There are now only eighteen licensed MCA sites in the UK with facilities to accept TEPs. They're shown on the map below and listed in this downloadable leaflet.
No criticism of the Coastguards whatsoever is intended. The folk in all the ops rooms, to whom I spoke, went out of their way to help. I've also spoken to some of the guys who actually receive the TEPs, and again, they try their best.
Everyone seems all too aware of the limitations of the new system, and are all trying to prevent accidents.
Each area is slightly different, so this is roughly how it works.
You telephone the listed MRCC for your area and they tell you on which specific days they will be able to accept your TEP. In some areas it is just one day a month.
They will also tell you to what location you should take the TEP - it's not necessarily the main MRCC.
As I said above, there are just four locations for the whole of mainland Scotland (there is also one in Stornoway and one in Shetland). And there is just one disposal location, yes ONE, for the entire mainland west coast.
You can't just turn up. You must make a reservation for a specific date, and in some cases, time, plus tell them exactly how many TEPs you are bringing. I was told this is because a private company supplies a box to hold the TEPs and, when it's full, they can't take any more until a new box is delivered.
It is perfectly legal to transport TEPs to the disposal site in a car. The regulations apply to places of work and places in public use, not individuals.
But....
Is every sailor going to go to all that fuss, make arrangements weeks in advance to spend hours in a car and an awful lot of petrol, to driving to a disposal site?
Or will they quietly dump them? Irresponsible and illegal. But much, much easier.
Imagine you live on an island, like one of the Orkney Islands, without a collection point. You're not allowed to transport out of date flares on ferries or aircraft. So how are you legally going to take them to a collection point? This is being discussed on an Orkney forum (you have to register to read it).
Shetland Coastguard told STV last August that people were recklessly dumping flares. "This is now becoming a regular occurence in Shetland", said John Webster, sector manager. "To us it is only a matter of time before somebody gets killed or seriously maimed..." And Shetland has a collection point, so imagine how bad it could be elsewhere.
However, dumped flares might not be the consequence of the system change. Fishermen and other commercial boat users are meant to use private companies to dispose of their flares, and that can be expensive.
Some marinas have begun accepting leisure boater's TEPs, although they charge a small fee and don't advertise the facility. Maybe they fear being swamped with the things?
I recently disposed of four TEPs at Largs Yacht Haven marina office at £1.50 each. I was not expected to buy replacements, although I did go next door to the chandlers and purchase two day/night flares.
Some councils may also have licensed sites for explosive disposal, but I can't find a list.
So what's to be done?
The MCA is not responsible for the disposal of out of date flares but, helped by the Department for Transport, has worked hard to put in place a system which won't charge users. The MCA received no extra government money for this.
The RYA was asked by members to make representation to government.
It takes the view "it is unrealistic... to expect to be able to buy flares at the cheapest price possible, often from mail order or the internet, and then expect someone else to be responsible for their disposal when they become out of date; they are the responsibility of the person that purchased them."
"If you are unable or unwilling to travel to the disposal sites provided, there are commercial companies that will dispose of your unwanted TEP, although the cost may be significantly more...." Download FAQ sheet.
Apparently, there have been attempts to build the price of disposal into the purchase price of flares. These have been resisted by distributors who know they'd be at a significant disadvantage to overseas imports and online purchasing.
For now, if you're going to buy a flare, I suggest you go to somewhere that guarantees to dispose of it when it expires in three or more years time. But would that guarantee hold, I wonder?
Disposal must be part of the purchase decision of flares.
So from now on, the only ones I'll buy are the day/night type, useful for giding in a helicopter or smaller lifeboat when close.
For raising the alarm I'll rely on my radio, phones and PLB for raising the alarm.
Rocket flares will be retired and not replaced as they expire.