SDR 2025: What Six New Energetics Factories Mean for WOME Safety Case Requirements

The Industrial Commitment in Context

When the Strategic Defence Review (SDR) was published on 2 June 2025 — the most significant reshaping of British defence since the Cold War — its headline commitments centred on GDP targets, nuclear deterrence, and platform procurement. Buried within those headlines, however, was a commitment with profound and immediate implications for the WOME professional community: the construction of at least six new energetics and munitions factories, backed by a £6 billion munitions investment across this Parliament. Of that total, £1.5 billion is specifically allocated to energetics factory infrastructure — the reconstitution of a sovereign manufacturing capability that, by the government's own admission, has been dormant for nearly two decades.

This is not simply a procurement announcement. It is the physical reconstitution of a UK energetics industrial base that closed down in the early 2000s. The implications for safety case development, regulatory compliance, site licensing, workforce competency, and the wider WOME professional community are substantial — and the timelines are aggressive. The Defence Secretary has publicly stated the expectation that construction will begin on the first factory in 2026. Engineering design work on that first facility has already been commissioned.

What Will These Factories Produce?

The Ministry of Defence has been unusually specific about the energetic materials it requires. A published Planned Procurement Note (PPN) identifies nine priority energetic materials — with other propellants, detonators, ignitors, and pyrotechnics considered on an exceptional basis. The list covers the full spectrum of military explosives and propellant chemistry:

The breadth of this list is significant. It encompasses primary explosives chemistry (RDX, HMX), melt-cast explosive manufacturing (TNT), double- and triple-base propellant production (NC, NG, NQ), insensitive munitions formulations (HNS), oxidiser synthesis (AP), and pyrotechnic manufacture (BKNO₃). Each material carries distinct processing hazards, handling requirements, Quantity-Distance (QD) planning implications, and incompatibility considerations. No single safety case framework or site licence template will suffice across all six factories — each facility's safety case will need to be developed from first principles against its specific energetic material portfolio.

The Sites: A National Industrial Footprint

The MoD has identified thirteen candidate sites across the United Kingdom as potential locations for the new energetics and munitions factories. These span a wide geographic footprint, reflecting the government's dual objectives of distributing economic benefit and leveraging existing industrial and chemical infrastructure. The sites are to be considered as candidates at this stage — the MoD is conducting funded feasibility studies and has not publicly confirmed final site selections. WOME practitioners advising on any of these programmes should note that site-specific QD planning, HERO baseline assessments, and COMAH jurisdictional mapping will vary materially between locations.

Open-source reporting and FOI disclosures have confirmed the following thirteen candidate areas. Where the site is associated with a named existing facility or has been the subject of media reporting, additional context is provided:

Additionally, Loch Long / Finnart Oil Terminal in Argyll and Bute has been noted in open-source reporting as a candidate with potential marine logistics advantages for bulk energetic material handling. The full list of potential sites — and the specific facilities planned for each — remains subject to feasibility study outcomes and final MoD investment decisions.

Project NOBEL: The MoD Programme Behind the Programme

What the SDR announced publicly as a commitment to new energetics factories had already, by February 2025, been given an internal MoD programme identity. Project NOBEL — revealed via a Freedom of Information request to Scottish investigative outlet The Ferret — is the internal codename under which the UK's energetics factory programme is managed within the Ministry of Defence. Its existence confirms that serious programmatic activity predates the June 2025 SDR publication; NOBEL was active from at least February 2025.

The FOI disclosure identified three companies engaged in initial feasibility work under Project NOBEL:

• NIOA — Australia's largest privately-owned defence company, with significant munitions manufacturing experience across NATO-standard artillery ammunition. NIOA's reported interest is in the Ardeer site in Ayrshire, which has deep historical roots as a centre of British explosives manufacturing dating to the Nobel Industries era.
• CzechoSlovak Group (CSG) — A major Central European defence manufacturer with extensive munitions production capability. CSG's interest is reported in relation to the Broughton Moor site in Cumbria — the former Royal Naval Armaments Depot, which already carries a defence land designation and has significant existing infrastructure.
• Chemring Group plc — The UK's largest listed defence and security company, already operating at Stevenston in North Ayrshire (adjacent to the Ardeer candidate site). Chemring has existing DOSR-regulated licensed sites and established WOME safety management infrastructure, giving it a regulatory baseline advantage over new market entrants.

The public procurement process runs in parallel: the MoD has published a Planned Procurement Note (PPN) inviting industry proposals, with the three stages of Feasibility Study, Front End Engineering Design (FEED), and MoD Investment Contract representing the procurement gateway structure. Project NOBEL provides the internal programme management structure through which these stages are governed.

The Glascoed Precedent: Real-World Evidence of Timeline Risk

Abstract warnings about timeline risk in energetics factory construction tend to be treated as theoretical caution. The BAE Systems facility at Glascoed, Monmouthshire provides concrete, real-world evidence that they should be treated as central planning assumptions.

Glascoed was targeted to become operational in summer 2025, producing 155mm artillery shells at a rate substantially higher than any existing UK capability. As of February 2026 — eight months beyond the planned operational date — the factory building is physically complete but the facility is still not in production, undergoing testing and validation activities.

The root cause reported by The Guardian (15 February 2026) is instructive for WOME safety case professionals. During the construction phase, BAE Systems took the decision to increase production capacity by approximately 16 times the originally planned rate — a significant mid-programme scope change driven by evolving operational demand signals. This capacity expansion required engineering redesign, and the consequent testing and validation programme has extended the facility's entry into service well beyond the original schedule. BAE has invested £150 million across its UK munitions sites in this period.

The Regulatory Framework: DSA 03.OME and the DOSR

Any new energetics manufacturing facility operating within the MoD's sphere — whether directly owned, contracted, or supply-chain adjacent — must demonstrate compliance with the DSA 03.OME framework, administered by the Defence Ordnance, Munitions and Explosives Safety Regulator (DOSR). Understanding this framework is the first prerequisite for any organisation intending to develop a safety case for a new energetics facility.

DSA 03.OME Part 1 — Acquisition Safety Management

Formerly published as JSP 520, DSA 03.OME Part 1 is the Defence Code of Practice for OME Acquisition Safety Management. It applies throughout the entire acquisition cycle and mandates a series of regulatory requirements, processes, inputs, and outputs that must collectively support a claim that the inherent risks from OME are As Low As Reasonably Practicable (ALARP) — or, where this cannot be demonstrated, Broadly Acceptable.

Part 1 covers the full Manufacture to Target or Disposal Sequence (MTDS): from initial materials synthesis through processing, assembly, in-service storage, transportation, deployment, and eventual disposal. For a new energetics factory, the MTDS assessment begins the moment energetic precursor materials enter a facility. The Safety and Environmental Case Report (SECR) and Safety and Environmental Management Plan (SEMP) required under Part 1 will be the primary documents scrutinised by DOSR during the licensing and approval process.

WOME practitioners should also note that DSA 03.OME Part 1 DCOP 103 — the updated Defence Code of Practice for Safety and Environmental Case documentation — provides revised guidance on the structure and content requirements for SECR submissions. Organisations preparing safety cases for the new factories should ensure they are working to the current DCOP 103 requirements rather than legacy JSP 520 templates, which will not satisfy current DOSR expectations.

DSA 03.OME Part 2 — Storage and Processing

Now published as DSA 03.OME (replacing the withdrawn JSP 482), Part 2 provides the detailed Codes of Practice for the safe storage and processing of OME. For an energetics factory, Part 2 is arguably the more operationally immediate reference document, covering explosive building classifications, process hazard areas, personnel limits, Quantity-Distance separation, and explosive limits for individual buildings and site totals.

Where Part 2's Codes of Practice are not followed, DOSR requires that written justification be documented in the SECR. This means that any facility developer seeking to innovate on processing methodology, employ novel architectures, or integrate automated manufacturing that deviates from legacy CoP assumptions must engage with DOSR early — not late — in the design process.

Critical Regulatory Updates: What Factory Developers Must Know Now

Four DOSR Regulatory Notices issued in 2024–2025 will have direct and material impact on the planning and safety case development for the new energetics factories. WOME professionals advising on or working within these programmes must be current on all four.

The Safety Case Architecture for a New Energetics Factory

Developing a compliant safety case for a new energetics manufacturing facility is not a single document exercise. It is a structured programme of work, beginning at the concept stage and evolving continuously through design, construction, commissioning, and operations. The following represents the minimum architecture that WOME safety professionals should expect to build or advise on:

1. Preliminary Hazard Analysis (PHA) and Concept Safety Case

At feasibility study stage — and the MoD has confirmed it is funding feasibility studies for prospective factory developers — a Preliminary Hazard Analysis must identify all credible hazard scenarios associated with the proposed energetic material portfolio. The PHA feeds a Concept Safety Case that documents the design intent, key safety claims, and the evidence programme required to substantiate those claims at subsequent design stages. As the Glascoed precedent demonstrates, the energetic material portfolio locked at PHA stage must be the portfolio the facility is actually built and validated to process. Subsequent increases in production rate or material scope trigger mandatory safety case revision.

2. Design Safety Case and Hazard Log

As the facility moves through Front End Engineering Design (FEED) and into detailed design, the Hazard Log must be maintained as a living document capturing identified hazards, the design measures proposed to control them, and the residual risk following those controls. The Design Safety Case must demonstrate that all reasonably practicable hazard controls have been incorporated, and that any residual risks meet the ALARP standard. The SECR produced at this stage must conform to DSA 03.OME Part 1 DCOP 103 requirements.

3. HERO Analysis (Hazards of Electromagnetic Radiation to Ordnance)

All facilities handling EED (Electro-Explosive Devices) — detonators, initiators, fuzes — require a HERO analysis. With modern industrial facilities incorporating extensive wireless control systems, industrial IoT, automated guided vehicles, and mobile communications infrastructure, HERO has moved from being a relatively contained technical exercise to a system-wide risk management challenge. Any new energetics factory incorporating Industry 4.0 manufacturing technologies must ensure HERO analysis is integrated into the overall electromagnetic environment (EME) design from the outset, not retrofitted after installation.

4. Major Accident Control and COMAH Interface

Energetics factories handling large quantities of explosive materials will likely fall within the scope of the Control of Major Accident Hazards (COMAH) Regulations 2015, regulated by the Health and Safety Executive (HSE) and the Environment Agency (EA) for civil sites, with a defence interface through DOSR. The relationship between the MoD safety case framework (DSA 03.OME) and COMAH obligations must be carefully managed to ensure that the safety case satisfies both regulatory regimes without creating contradictions between arguments. For overseas-owned companies (NIOA, CSG) operating under Project NOBEL, this dual-regulatory interface will require early and co-ordinated engagement with both DOSR and HSE.

The Workforce Competency Gap: The Problem Nobody Is Talking About Loudly Enough

Physical construction is the visible dimension of the energetics factory programme. The less visible — and arguably more urgent — challenge is human. The UK's energetics industrial base closed down nearly two decades ago. There are, consequently, very few individuals in the UK commercial sector with direct experience of energetics manufacturing safety management, explosives processing safety case development, or the operational WOME competency required to commission and run these facilities safely.

The MoD's own WOME Competency Framework — administered through the Defence Academy and the Defence Weapons, Ordnance, Munitions and Explosives Engineering School (DWES) — currently has approximately 200 students enrolled in its two-year apprenticeship programme. This is a meaningful start. But against the scale of competency need implied by at least six new factories, the production of complex weapons programmes, and the broader SDR upskilling agenda, it represents a fraction of what is required.

The MoD's procurement process for the new factories explicitly offers assistance with "engagement with regulators" as a support element for viable proposals. What it does not — and cannot — do is conjure experienced WOME practitioners from an institutional base that was systematically wound down. That knowledge must be rebuilt through structured competency development, and it must start now.

What This Means for Industry: ISC's Assessment

For organisations entering the energetics factory programme — whether as lead developers, Tier 1 contractors, or specialist WOME consultancies — the following represents ISC's assessment of the critical actions required in the near term:

1. Engage DOSR at feasibility stage, not FEED stage. The regulatory notices issued in 2025, including the Project COWLEY QD methodology change and DCOP 103 SECR requirements, create significant risk for any facility design work that begins without current DOSR engagement. DOSR is explicit that it will engage with prospective factory developers — use that opportunity early.
2. Build the safety case team before you build the facility. The safety case programme for a new energetics factory is a multi-year exercise requiring specialist WOME expertise from concept through commissioning. That team needs to be constituted now — not when detailed design begins. The Glascoed experience confirms that late-stage scope changes make this even more critical.
3. Conduct a HERO baseline assessment at site selection stage. Site selection should incorporate electromagnetic environment assessment as a primary criterion, not an afterthought. HERO constraints can render an otherwise suitable site uneconomical to operate if fixed transmitters, mobile network infrastructure, or industrial IoT systems cannot be managed within Category 1 and 2 distance requirements.
4. Map your COMAH / DSA 03.OME interface from day one. Regulatory complexity across two frameworks with separate competent authorities is a known risk factor. For Project NOBEL participants NIOA and CSG — as non-UK entities — this interface will also involve additional security and ownership vetting requirements. A clear regulatory map, agreed with both DOSR and HSE at the outset, will save significant time and cost during licensing.
5. Lock your energetic material portfolio at Concept Safety Case stage and hold it. The Glascoed case study is the most direct available evidence that mid-programme scope increases — however operationally justified — translate directly into schedule delay and additional safety case work. The six factories being planned now must have their production scope defined, pressure-tested, and committed before detailed design begins.
6. Invest in WOME competency development as a long-term programme, not a short-term recruitment exercise. The MoD Competency Framework provides the structure. ISC's training division can provide the curriculum. The organisations that invest in building their own WOME-competent workforce now will be the ones operating safely at full production capacity in 2029.

Conclusion: Safety Case Work Begins Before Ground Is Broken

The SDR 2025 energetics factory commitment is not a future aspiration — engineering design on the first facility is already commissioned, groundbreaking is expected this year, and Project NOBEL has been running since at least February 2025. The safety case architecture that will govern these facilities must begin to take shape now, not when contractors arrive on site.

The Glascoed factory — the most advanced example of the UK's current munitions manufacturing ramp-up — is not yet in production as of February 2026. That is not a criticism; it is a data point. It tells the WOME community that safety validation at an energetics facility takes the time it takes, and that scope changes mid-programme cost schedules that cannot easily be recovered. For the six factories that follow, the lesson is that the safety case programme, the DOSR engagement, and the competency infrastructure must be established as a first-order priority — not a second-order consequence of construction activity.

The UK has an opportunity to build a world-class energetics manufacturing capability that meets NATO interoperability standards, satisfies the most rigorous safety case frameworks, and is staffed by a new generation of WOME-competent practitioners. Realising that opportunity requires the WOME professional community to engage with this programme with the same urgency the government is applying to its physical construction.

ISC Defence Intelligence will track the development of the energetics factory programme, DOSR regulatory updates, and workforce competency developments as a running editorial priority. Subscribers to the WOME Brief newsletter will receive regulatory update alerts directly to their inbox.