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is this the beginning of the end


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#1 martyn

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Posted 10 May 2010 - 06:04 PM

We all know what we do is naughty - some of us kid ourselves that we are allowed to do it under the '100g experimental' exemption, even though fashioning something into a firework probably definately constitutes 'practical use'.

In a bored moment I stumbled across this recent document which to my reading indicates that HSE are considering reducing the 100g figure to "a few grams or less".

You may have to register on the hse explosive web community to access the files. If you do register you will probably get an email inviting you to join a group which comprises of "
representatives of industry, regulators and other interested parties of all GB

health and safety explosives legislation. It will simplify and clarify this legislation and underpinning guidance, delivering in 2012". Hopefully some of you 'more cleverer than me' might contribute to it?

The excel file can be downloaded here
Issues for consideration in the ELR - all legislation 040510

The bit I'm referring to is on the mser tab, line 31.

If anyone is interested and can't access the file I can email it to you.

Martyn

#2 BrightStar

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Posted 10 May 2010 - 07:25 PM

Yes this suggests a change, but the UKPS is well aware.

The HSE have agreed some level of consultation in advance of any modifications. As such, there are avenues open for us to explore.

#3 phildunford

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Posted 10 May 2010 - 07:40 PM

Does not seem to want to let me in...

Yes, as Brightstar says, we were aware this is on the cards.

My personal opinion is that it would be counterproductive to the HSE to make matters worse for experimenters. The sensible solution would be to give us a legal route to the hobby.

I would also observe that the 100g limit does not allow us to make fireworks, so it's abolition would not actually change anything.
Teaching moft plainly, and withall moft exactly, the composing of all manner of fire-works for tryumph and recreation (John Bate 1635)
Posted Imagethegreenman

#4 pyrotechnist

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Posted 10 May 2010 - 09:33 PM

Bring back the small explosive license again!

I dont see the point in these regulations anyhow, yes we need them for manufacturing to be safe enough etc but simply not allowing for experimentation or allowance of small manufacture for personal use or even SME's is plain stupid. They can throw as many laws or regulations at people as they may wish but people will still do it no matter what. Same with guns, they are banned but they still buy and use them and the thought of going to prison to some is nothing but a holiday boot camp.

Now B**bs these days seem to be made more with household ingredients that are easier to obtain than the chemicals we use so why do they penalise us with the actions of a small minority? They seem to be working to an outright ban here by restricting fireworks so much that people will lose faith in them and think of them as a waste of money and simply stop buying them. This will in effect make the fireworks industry destroy itself and then make out that the government had nothing to do with it.

The government need to lay off these regs and put a tariff on imports to make importing items expensive and none-feasible so that our manufacturing base can kick off again. Just like it used to be until they stopped it and our textile industries and pyro industries etc collapsed due to cheap foreign imports. Look at news articles from yesteryear to see the handy work of our government in destroying our manufacturing base and turning us into a cheap laughable service economy. We need the pyro industry back before it is to late and it would be nice if some higher order pyro companies could fully support the UKPS in its goals as soon they will be effected if not all ready by our doomed laws and economy.

Enough said from me :).

Edited by pyrotechnist, 10 May 2010 - 09:45 PM.

fireworks is my aim setting of is the game

#5 blasterbert

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Posted 11 May 2010 - 05:21 AM

no matter what they bring in it wont stop me :D :D .

#6 crystal palace fireworks

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Posted 11 May 2010 - 07:56 AM

I too can`t seem to access this info without registering,....can the UKPS display a copy of the info for us to view?

#7 phildunford

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Posted 11 May 2010 - 08:00 AM

I too can`t seem to access this info without registering,....can the UKPS display a copy of the info for us to view?


I registered, but it's still in a closed group. I have however seen a copy. I suspect we would be on very shaky ground to republish such material...

However, the content that is relevant to us is indeed exactly as has been stated and it's an issue we must address.
Teaching moft plainly, and withall moft exactly, the composing of all manner of fire-works for tryumph and recreation (John Bate 1635)
Posted Imagethegreenman

#8 crystal palace fireworks

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Posted 11 May 2010 - 08:41 AM

We all know what we do is naughty - some of us kid ourselves that we are allowed to do it under the '100g experimental' exemption, even though fashioning something into a firework probably definately constitutes 'practical use'.

In a bored moment I stumbled across this recent document which to my reading indicates that HSE are considering reducing the 100g figure to "a few grams or less".

You may have to register on the hse explosive web community to access the files. If you do register you will probably get an email inviting you to join a group which comprises of "
representatives of industry, regulators and other interested parties of all GB

health and safety explosives legislation. It will simplify and clarify this legislation and underpinning guidance, delivering in 2012". Hopefully some of you 'more cleverer than me' might contribute to it?

The excel file can be downloaded here
Issues for consideration in the ELR - all legislation 040510

The bit I'm referring to is on the mser tab, line 31.

If anyone is interested and can't access the file I can email it to you.

Martyn


Hi Martyn, please can you email me the file!

#9 Richard H

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Posted 11 May 2010 - 10:19 AM

Hello,

The UKPS is fully aware of the Explosive Legislative Review, and actually we are now a part of it. Our representative Wayne Robshaw is a part of MSER 3 Working Group. I will ask Wayne to post here and provide you all with the opportunity to give your thoughts and opinions.

R

#10 wayne

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Posted 12 May 2010 - 07:35 AM

Hello,

The UKPS is fully aware of the Explosive Legislative Review, and actually we are now a part of it. Our representative Wayne Robshaw is a part of MSER 3 Working Group. I will ask Wayne to post here and provide you all with the opportunity to give your thoughts and opinions.

R


Thanks Richard for the heads up.

Be assured that a lot of work is going on in the background to help clarify the current and future explosive legislation in relation to activity by UKPS members. I have been in talks with the HSE since August 2008 with a view of representing the interests of UKPS. This has been a very slow process which at the current moment is becoming interesting with the creation of the ELR. I am now a member of the work groups primarily interested in the manufacturing side of MSER. I have also requested membership to the COER workgroup as there is a little cross over.

The current strategy is to clarify the current 100g regulation (reg 9.2.a) and possible create a new one to allow for small scale manufacture. The current questions raised over reg 9.2.a (lowering the limit of 100g, clarification over what is defined as a laboratory etc) have all arisen due to the current talks with HSE. Those are all questions we have posted to them which they are now opening up in the review. At this stage its all out in the open and up for discussion, so its not necessarily a bad thing. Be assured that I will be voicing the concerns of the UKPS membership at any tightening of the current regulations.

I will try and keep you all updated as much as possible, but I'm sure you appreciate that progress with any amendments to legislation is very slow.

If you have any specific questions about the review or our stance in the ELR, feel free to ask.

Cheers,

Wayne

#11 martyn

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Posted 12 May 2010 - 03:31 PM

Hi Wayne – thanks for chipping in. I hadn’t realised that all this work was going on in the background.

In order for you to be able to represent us (UKPS members), it might be an idea if you knew of what we would like from the legislation. Apologies if this has been covered before I became a member.

I’ll start with what I would like.

I would like to be able to buy the necessary chemicals legally easily and at the market rate for the qty I am buying. At the moment this is achievable but only due to the generosity and competence of one or two members.

I would like to be able to make / buy / store black powder (and variants) in small quantities, say the same limit as imposed in mser on the muzzle loading community. Obviously as the product is essentially the same the storage requirements should be the same – ie approved box , small jars, not in escape route, etc etc. Although allowed I would not dream of keeping it in my house! I would limit my bp milling batch size to whatever they / we thought reasonable and if necessary comply with separation distances and remote operation.

I would like to be able to make and store (separately from the bp if necessary), a similar quantity of other perchlorate / star type comps, either as a mixed powder or rolled into stars and stored in a similar way to the bp.

I would like to be able to store a qty of assembled fireworks, for a period of time, say 28 days. Not a huge amount, I’d have to think a bit about how much I might want to store, certainly be happy with something like, less than 10KG NEC – I do realise that is quite a lot (for me at least). I realise that the fireworks would not be cad approved but if standard construction techniques and standard comps were used I don’t see why something could not be worked out.

It would be nice to be able to make and if not store, immediately use a little flash and whistle.

I would happily obey the commercial rules regarding chlorate.

I would happily pay for training and have to pass an examination of competence.

I would happily be open to be inspected.

I would happily pay a reasonable licence fee, or even an unreasonable one!!.

Perhaps I am a bit dim / naive in thinking that this really isn’t that unreasonable, but the rocketry lot seem to have got somewhere.

What would others like. What are you (we) asking for?


Cheers

Martyn



#12 Guest_PyroPDC_*

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Posted 12 May 2010 - 04:37 PM

personaly out of all that i would just like to do this hobby safely and legally, at the moment technically we cant do anything (100g was never made for us so and no court of law would let us get away with it.) instead of pretending its ok to do i would like to be open with my hobbie, invite a inspector to show what im doing is safe and im not some 13 year old kid wanting to make the loudest bang.

its got to be a good thing wanting to be open to the HSE and legal instead of hiding and pretending it will be ok if the law caught us. as said before if the model rockety can get legalised why cant we.

Edited by PyroPDC, 12 May 2010 - 04:38 PM.


#13 maxman

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Posted 12 May 2010 - 04:54 PM

Wow Martyn, Thats one pretty nice wishlist! but dare I say you've got no chance.

To have the 100 gram rule clarified would be nice so I don't get raided or thrown in the slammer.

Even better to be able to make 100g BP and use it to make some devices (remember 100g would make 5x 4oz rocket motors) (without being thrown in the slammer) 100g will make a few small bore roman candles for star testing, a couple of 1lb gerbs etc. I would be happy not to use chlorate or flash as I never have anyway (my rules) I am happy to pay for licences, competence testing, paying insurance , paying for a small secure magazine etc.

I would like not to have to go through planning permission and having all details spread throughout the local rag and have to see if neighbours object. I think all the above would be the minimum requirements for some realistic research and experiments.

I am not interested in stockpiling explosives or made up fireworks for displays as my interests are in how effects are made. A 3" shell is big stuff for me.
Therefore if I was told tomorrow that as an amateur I could have 1kg of BP and 1kg of stars, either as powder, made stars or in devices this would be more than enough to keep me happy.


The bottom line is let me make a small firework but don't lock me up!

Maxman

#14 Alexander

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Posted 12 May 2010 - 04:56 PM

....even though fashioning something into a firework probably definately constitutes 'practical use'.


I would also observe that the 100g limit does not allow us to make fireworks, so it's abolition would not actually change anything.


I have been trying to find a thread or explanation on this, it doesn't help that 'hse' is too short to be an allowed search term ;)

The exemption is fashioned in such a way that includes the creation of a complete firework, arguing that 'practical' should be interpreted in such a way as to invalidate the primary legislation does not sound enforceable to me. I cannot find any official guidence on the exemption in the Approved Code of Practice either.

Could someone point me to something concrete?

#15 pyrotechnist

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Posted 12 May 2010 - 08:49 PM

I would just like the old small manufacturing license back which according to the old law used to cost a tenner :). This allowed for more than enough material for small manufacture.
fireworks is my aim setting of is the game




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