104 replies to this topic

[exat808]

You may also wish to have a look at Event Horizon ( or Precision Energetics as I think they are now branded). They host some of the SFX courses at their site in Somerset. Its a great training venue and the guy who runs the place is very knowledgeable ( Charlie Adcock).

[digger]

You may also wish to have a look at Event Horizon ( or Precision Energetics as I think they are now branded). They host some of the SFX courses at their site in Somerset. Its a great training venue and the guy who runs the place is very knowledgeable ( Charlie Adcock).

We tried to get this done as a course through the UKPS. However there were not enough takers to block book the course. I think the problem was the price.

However watch this space as there may be another option soon.

[pyrotechnist]

I hope this could be done, would be nice to have a qualification that says we are pyros , digger check your PM.

[phildunford]

Well a certifcate comes with passing the Illuminate or BPA courses and I guess that says you are a pyro - being a pyro only really comes with experience as we all know and there are no certificates for that...

The course we are considering is similar to the Event Horizon course in that it is really about special effects rather than pyro - could be interesting though! Watch this space.

[wayne]

Hi All,

The suggestion of employing a paid representative is a good one. The only issues here are cost and finding someone with expertise and influence that would take it on. I am open to suggestion if anyone has any ideas.

Exat808, you have made some interesting points. You sound to have some good experience in legislation so please let me know if you would like to be a member of the legislation committee.

I was referred to IExpE by my regional firearms/explosives officer. I have yet to formally join, but it would make sense from a competence point of view.

A quick resume of our current position. I have been liaising with the HSE since 2008 regarding the current and future legislation of experimental small scale pyrotechnics. We have drafted a proposal to how MSER Reg 9.2.a could be applied which has been submitted to the HSE for their consideration. This has now culminated in our participation in ELR. It has been a very slow process so far, but now the ELR has been setup thing should start getting more interesting.

If you would like to chat things over further feel free to PM.

Cheers,

Wayne.

Just in from the day job and catching up on this thread.
The creation of a suitably phrased disapplication to MSER Reg 9 would require consideration of a number of separate issues which when bolted together would give a legally sound basis of an exemption. Points to be considered might include -
1. What is to be manufactured? Use of the the terms "fireworks" and "pyrotechnic" would need careful consideration. MSER Reg 2 defines fireworks as articles classified under the UN system with the numbers 0333 to 0337. Fireworks manufactured by yourselves will be unclassified (unless submitted to HSE for a CAD which is not what you require the dissapplication for). Pyrotechnic also has a definition at Reg 2. this is a very loose definition designed to capture all pyro articles and substances. So - step 1 - define your product in a form of words that captures only what you seek to achieve and does not provide a legal loophole for potential misuse.
2. Where is it to be manufactured? Are you considering a wholly unrestricted approach to this matter or should the manufacture be restricted to specific locations for example by inclusion of wording in the disapplication such as "at the place of intended demonstration". A strong safety case will be expected to support either approach.
3. How much is to be made? Does 100gr work for the hobby at present of can you safely argue for more? Currently the HSE will advise that under the present MSER Reg9 dissapplication the making of a 100gr sample is acceptable for the purposes specified, but that the next 100gr sample made at the same site must differ from the first and so on.
4. What is the explosive to be used for? You must look at words or phrases that capture your intentions eg "experimentation", "testing", "research", "development".
5. What is the explosive not to be used for? As in 4 above you must exclude those activities that would indicate commercial manufatcure. "Not for sale", "Not for public entertainment purposes" come to mind?
6. What other restrictions? To tidy up any disapplication it may be prudent to offer up exclusions such as "the maximum amount of exposed pyrotechnic substance on the site shall not exceed **kg" "a maximum of **kg of completed articles shall be present on the site"

My thoughts above are not exhaustive by any means but having had many years experience of developing legislation it should give the forum something to consider.
Some views on black powder will follow after tea!!!

[martyn]

Hi All,

The suggestion of employing a paid representative is a good one. The only issues here are cost and finding someone with expertise and influence that would take it on. I am open to suggestion if anyone has any ideas.

Exat808, you have made some interesting points. You sound to have some good experience in legislation so please let me know if you would like to be a member of the legislation committee.

I was referred to IExpE by my regional firearms/explosives officer. I have yet to formally join, but it would make sense from a competence point of view.

A quick resume of our current position. I have been liaising with the HSE since 2008 regarding the current and future legislation of experimental small scale pyrotechnics. We have drafted a proposal to how MSER Reg 9.2.a could be applied which has been submitted to the HSE for their consideration. This has now culminated in our participation in ELR. It has been a very slow process so far, but now the ELR has been setup thing should start getting more interesting.

If you would like to chat things over further feel free to PM.

Cheers,

Wayne.

Wayne - I feel we should be asking for more than clarification / allowing of the 100g limit. Is that what you are asking for?

9.2a does not permit storage, transport, or indeed fabrication. The quantity is also far too small to be of much use practically (obviously as it is intended for......the purpose of laboratory analysis, testing, demonstration or experimentation (but not for

practical use or sale)...... )

Can you tell us what your proposal is proposing - we would all be very interested and would give us an idea or whether we are all singing from the same sheet.

Cheers

Martyn

PS - I suggested Tom Smith as a posible paid representative - this is because - he is the only 'expert' I have come across - Im sure there are dozens more though, he is a nice bloke, he has excellent expertise and credentials, he started at kimbolton and therefore MAY be sympathetic to amateur pyro.

Edited by martyn, 29 June 2010 - 10:07 AM.

[pyrotechnist]

Could we not bargain for the old small manufacturing license to be brought back as it was pre-drafted etc. Obv we would need to have a few changes etc but it is workable and usable. It would also be great for anyone wanting to venture into actually making pyro to sell if they ever wanted to head in that route. We need to get this industry back into Britain and I am sure some of the people on this forum will be some of the new pioneers in re-creating or changing our pyro industry and hopefully stabilizing it.

[wayne]

Hi Martyn,

That is exactly what we are doing. We started by trying to clarify the current regulations and in particular reg 9.2.a, with a view to see how this could be used for very small scale pyrotechnics. This indeed raises many questions over, fabrication (can a firework actually be assembled with the 100g of explosives manufactured), storage (100g of any explosives can be stored without a license, but what about a finished item?), what is deemed to be a "laboratory", what is classed as an experiment, etc, etc. There are so many questions that it becomes almost too onerous to contemplate. Therefore we took the decision to try and fit the current reg 9.2.a around what we're trying to achieve and let the HSE bounce back any issues they have with the proposals. In this way we can deal with each issue individually rather than trying to work out solutions to problems that might not actually be there! As it stands, I'm still waiting for a formal response from the HSE in reply to the proposals. They now tell me will be a part of the ELR. This is when the real work will start.

As mentioned previously, we have already delivered the proposal document to the HSE for their consideration. This has never been in the public domain since it could be counter productive to the matter in hand. I will consult with legislation committee for their view on whether this should be made a public document. As I'm sure you agree, nothing ever gets agreed if you have too many chiefs and this was the fear of making the document public.

As for the 100g limit, I think we have to start here. If/when this is given the green light by the HSE, we then look at further regulations to increase the amount. As I'm sure you agree, the amounts produced are always going to be a sticky area. In fact the HSE are already considering lower the 100g limit!

I hope this give a clearer picture of our current work with this, but please ask any further questions you wish.

Kind regards,

Wayne.

Wayne - I feel we should be asking for more than clarification / allowing of the 100g limit. Is that what you are asking for?

9.2a does not permit storage, transport, or indeed fabrication. The quantity is also far too small to be of much use practically (obviously as it is intended for......the purpose of laboratory analysis, testing, demonstration or experimentation (but not for

practical use or sale)...... )

Can you tell us what your proposal is proposing - we would all be very interested and would give us an idea or whether we are all singing from the same sheet.

Cheers

Martyn

PS - I suggested Tom Smith as a posible paid representative - this is because - he is the only 'expert' I have come across - Im sure there are dozens more though, he is a nice bloke, he has excellent expertise and credentials, he started at kimbolton and therefore MAY be sympathetic to amateur pyro.

[martyn]

OK Wayne - I'll leave it in your capable hands. Just out of interest what / who is the legislation cmtee? (is the site list up to date)
I agree absolutely that there should not be too many chiefs - what I am slightly suprised about is that you / the cmtee are representing us (the ukps members presumably) but as far as I know no one has ever asked what we would like.
I have given my 'wish list', you may feel that is over optimistic, but dozens of others have not.
That is genuinely not meant to be an arsey statement - just an accurate, I think, observation.
Anyway - please keep up the good work.

[pyrotechnist]

Dam even if you cant get a license for the hobbyist can they please not lower the price for a license and make it easier to get one .

[exat808]

I have PM'd Wayne and suggested a chat.

[martyn]

I have PM'd Wayne and suggested a chat.

Ah - excellent. Thank you.

[Richard H]

OK Wayne - I'll leave it in your capable hands. Just out of interest what / who is the legislation cmtee? (is the site list up to date)
I agree absolutely that there should not be too many chiefs - what I am slightly suprised about is that you / the cmtee are representing us (the ukps members presumably) but as far as I know no one has ever asked what we would like.
I have given my 'wish list', you may feel that is over optimistic, but dozens of others have not.
That is genuinely not meant to be an arsey statement - just an accurate, I think, observation.
Anyway - please keep up the good work.

Hi Martyn,

The committee list is accurate, with the exception of any new additions following a forthcoming conference call to discuss how we will progress this. It is clear now that the ELR must be one of our top priorities so that when the working groups commence, we have already hit the ground running. Wayne started these discussions on our behalf more than two years ago, so I see this really as the next chapter (and ultimately the culmination) of the process.

The committee I would to think has a very good awareness of what UKPS members would like to do - be able to experiment and keep within the legislation. At this stage I think it is a case of clarifying the 100g rule and putting forward use cases to HSE that show how our members might go about experimenting within that limit - and indeed the format of those experiments and so on. At this stage, there is little point asking what people would like, as it's just not going to work that way. Once the ELR is up and running and the working groups are talking, then begins the business of feeding back to UKPS members, and then putting forward thoughts, opinions, and suggestions via the committee. This is the approach we are taking.

With all due respect, the wish list you posted is wildly optimistic. Any successful outcomes we make certainly won't be on that scale.

R

[martyn]

Hi Martyn,

The committee list is accurate, with the exception of any new additions following a forthcoming conference call to discuss how we will progress this. It is clear now that the ELR must be one of our top priorities so that when the working groups commence, we have already hit the ground running. Wayne started these discussions on our behalf more than two years ago, so I see this really as the next chapter (and ultimately the culmination) of the process.

The committee I would to think has a very good awareness of what UKPS members would like to do - be able to experiment and keep within the legislation. At this stage I think it is a case of clarifying the 100g rule and putting forward use cases to HSE that show how our members might go about experimenting within that limit - and indeed the format of those experiments and so on. At this stage, there is little point asking what people would like, as it's just not going to work that way. Once the ELR is up and running and the working groups are talking, then begins the business of feeding back to UKPS members, and then putting forward thoughts, opinions, and suggestions via the committee. This is the approach we are taking.

With all due respect, the wish list you posted is wildly optimistic. Any successful outcomes we make certainly won't be on that scale.

R

OK Richard, fair enough. I'll keep quiet and wait and see what develops. One thing though, I would not really call what I do 'experimenting' - that may come later with more knowledge and experience.
What I'd enjoy, and I suspect many others, is making a few stars / shells / fountains / whatever and then firing them for my own enjoyment, albeit tempered by having to always be looking over my shoulder.
I'd prefer to call it hobby production.
I'd like to be able to use published proven (passfire type) compositions and standard accepted fabrication methods. Being able to legally mix up a few grams of composition striving for the perfect blue, whilst interesting and enjoyable for experimentation, is not what I personally, and I'm sure many others would like from the review. If the 100g nonsense were to be ratified, you'd still have amateur pyros up and down the country milling 400g batches of bp and rolling batches of stars exceeding that limit.
If I were younger and didn't have a wife and 3 kids - I'd seriously consider moving to a pyro friendly US state!!

[Vic]

I think most amateur pyro's when starting off don't even know about the 100g rule or don't care .
You are not going to stop people from making bp and putting it into tubes even if there was a legal route and I doubt if many would be able or willing to conform. For most making experimental fireworks it is a short lived affair except a few dedicated fellows where it becomes a life long hobby.

I would like to see a time when I can make some test stars and fire them singly from a tube in my back garden, also try small fountains and lances and when the firework season is with us to be able to make small cakes, rockets, shells and the like.

Most of all if I could transport small quantities of bp, whistle, strobe mix to a suitable launch site to make rockets or better still the rockets themselves .
Ho I have ended with a wish list haven't I.