57 replies to this topic

[digger]

Will the Acquire and Keep also cover the storage of pyrotechnic devices? (Those made for testing, demonstration or experimentation).

 

To further clarify storage will still come under existing storage rules.

 

The issuing body is generally determined by what and how much you are storing. So if it is less than 2 tonnes NEQ and UN numbers pertaining to fireworks/fuse/stage pyro etc then it is either trading standards or the fire brigade depending on your local council structure (most commonly trading standards). However if some of the UN numbers relate to compositions or devices that require a COER certificate then the licensing authority is the Police.

 

If you wish to store more than 2 tonnes NEQ then the licensing authority becomes the HSE

 

The requirements for storage are different between the Police and trading standards. I am not completely sure of the exact requirements under all circumstances.

 

Basically for trading standards a secure wood lined container is sufficient (the may ask you to earth it, but this can usually be argued away with the faradays cage principle).

 

For a Police inspected store this is a little more complicated. If it is 15kg or less of black powder or some other weight I forget of shooters powders then it can be stored in your house in a suitable container. However if it is anything else then it will have to be follow the usual separation distance tables in MSER and the Police also stipulate a monitored alarm system (not connected to the police) which is activated by two individual trips to prevent false alarms. The stores that they like to see are substantial units for which there is a British standard (I forget the number). There are a number of manufacturers of these stores, companies such as Hornsby and Goodwyn.

 

I hope this helps

 

P.S. One further note, you can of course store 5kg of HT4 indefinitly without licence.

 

Edited by digger, 26 March 2014 - 02:18 PM.

[Rip Rap]

Thanks Digger,

 

that does clarify certain points.

 

I suppose what I was trying to ascertain is whether an "experimental" pyrotechnic device will be covered by existing storage rules? As by definition it would have no UN number, British Standard classification, Hazard Type etc (or would it??)

 

Otherwise, any experimental device could not be stored and would have to be fired immediately after construction.

[digger]

Thanks Digger,

 

that does clarify certain points.

 

I suppose what I was trying to ascertain is whether an "experimental" pyrotechnic device will be covered by existing storage rules? As by definition it would have no UN number, British Standard classification, Hazard Type etc (or would it??)

 

Otherwise, any experimental device could not be stored and would have to be fired immediately after construction.

 

Unfortunately pretty much everything has a UN number. For instance flash powder is UN 0305.

 

However the rules allow for the storage of 100g of any explosive or device without the need for a storage certificate. But you would need a COER cert if it contained flash or black powder. If you wanted to make a device and store it whilst making another which you then store you may or may not need a storage licence depending on the Hazard type and whether it falls under COER.

 

Storage is all about Hazard type. Hazard type can be determined by YOU, you should do a risk assessment and determine the hazard type of anything you make for storage purposes.

 

Classification is something entirely different, this relates to transport by road and placing upon the market. This is a huge minefield that you will not have to get into with this legislation unless you want to become a manufacturer.

 

By the way there is even a UN number for unclassified devices to allow them to be transported by road to a place of testing, of course this defaults to HT1 as a worst case.

 

If you are interesed in the storage rules I suggest you download the MSER 2005 ACOP from the HSE books website (free) and look at the tables in the back of the book, this explains quite clearly the the requirements for various hazard types. You will notice that the table that relates to process buildings starts at 100g, this is why we would not need a classified/licenced process building for making experimental devices.

 

Gareth

[maxman]

However the rules allow for the storage of 100g of any explosive or device without the need for a storage certificate. But you would need a COER cert if it contained flash or black powder. If you wanted to make a device and store it whilst making another which you then store you may or may not need a storage licence depending on the Hazard type and whether it falls under COER.

 

Storage is all about Hazard type. Hazard type can be determined by YOU, you should do a risk assessment and determine the hazard type of anything you make for storage purposes.

 

 

 

Very interesting information Gareth. I'm following this thread with great interest and of course I guess all will be revealed in due course but are you saying that with the acquire and keep etc then 100g max can be made at any one time but then if that 100g is made into say 5x 20g gerbs of different id tubes or added metal powders then they could risk assessed as HT4 and stored as such while another 100g is made into say 5x 20g rockets etc to be tested at a later date?

 

Rod

[digger]

Rod

 

The final guidance is scheduled to be published later this year.

 

However it is my understanding that your premise is correct assuming you are talking about gerbs and rockets that require black powder based compositions.

 

If they were gerbs and rockets that were not black powder based then you would not even require a COER certificate.

 

I am not sure yet, but you may even be able to make 5 identical units, for instance to test repeatability.

 

Gareth

[cooperman435]

Just to add, be aware that if you were to add 20g of a metal powder to 100g of a composition it would become PART of that composition and therefore result in 120g of composition, 20g over the permitted amount.

[maxman]

Hi Phil, yes I did realise that and it was a bad example on my behalf written in the heat of excitement after reading the thread

 

 

I was quite shocked (in a good way) and also slightly worried at the same time regarding the quote "Storage is all about Hazard type. Hazard type can be determined by YOU, you should do a risk assessment and determine the hazard type of anything you make for storage purposes."

 

I'm sure different people will have different views on what hazard type is what if it is down to the individual to decide. Does that not lead to all sorts of potential issues? and who will police this?

 

Rod

[phildunford]

My suspicion (for what it's worth) is that no one will police it. Now we are legal are can't see that it's worth anyones trouble to monitor minor matters concerning experimentation.

[cooperman435]

I think the point has been missed, it's not about policing the issue, it's about being appropriate in your actions.

The regulations we abide by have changed very little however our use of them and their importance to legalise our activities have, along side out work with ELR.

We CAN now be recognised as legal, assuming appropriate steps are taken and as always some or many of these steps are down to the individual who ultimately must answer to the decisions they make if asked about them.

The issues and decisions are not "policed" but must be self policed so they can later be justified if needed. If you do something unsafe or wrong you will / may struggle to do so.

This is not a get out of jail card it is simply the opportunity to work within a window to have a legal precedent to back you up should the worst happen.

Edited by cooperman435, 27 March 2014 - 10:55 AM.

[martyn]

Unfortunately pretty much everything has a UN number. For instance flash powder is UN 0305.......

Gareth

Hi Gareth, do you know what the difference is between 0305 flash powder and 0094 flash powder?

One seems to be 1.1 and the other 1.3?

source is here

Cheers

Martyn

[digger]

Hi Gareth, do you know what the difference is between 0305 flash powder and 0094 flash powder?

One seems to be 1.1 and the other 1.3?

source is here

Cheers

Martyn

 

I think in practice it will be determined by the transport packaging (UN number realate to transport of chemicals) , clearly one is packaged to be a thermal hazard only and the others packaging is not sufficient to prevent simultaneous explosion of all packages.

 

 

I was quite shocked (in a good way) and also slightly worried at the same time regarding the quote "Storage is all about Hazard type. Hazard type can be determined by YOU, you should do a risk assessment and determine the hazard type of anything you make for storage purposes."

 

I'm sure different people will have different views on what hazard type is what if it is down to the individual to decide. Does that not lead to all sorts of potential issues? and who will police this?

 

Rod

 

It is quite clear what hazard type something is.

 

HT 1: An explosive which, as a result of, or as a result of any effect of, the conditions of its storage or process of manufacture has a mass explosion hazard

HT 2: An explosive which, as a result of, or as a result of any effect of, the conditions of its storage or process of manufacture has a serious projectile hazard but does not have a mass explosion hazard

HT 3: An explosive which, as a result of, or as a result of any effect of, the conditions of its storage or process of manufacture has a fire hazard and either a minor blast hazard or a minor projection hazard, or both, but does not have a mass explosion hazard:

HT 4:an explosive which, as a result of, or as a result of any effect of, the conditions of its storage or process of manufacture has a fire or slight explosion hazard, or both, with only local effect

 

So if I were doing a risk assessment knowing the properties of an item I could clearly put it into one of the above classes. I could even change the class it falls in by the way I store it. Clearly 4 or 5 10g salutes sat on a shelf would be HT 1 as they would all go off together if one was initiated. However if I stored each in the centre of a 20cm triple walled box filled with pearlite I could probably argue that it is HT 4 for storage as the effect would not even get out of the box.

 

However if I have 50 grams of some new powder and I do not know how it behaves, I would probably asses it as HT 1 until I have tested its properties.

 

I have had discussions with the HSE in the past about Hazard types and it all boils down to understanding what they are and making a sensible well informed judgement on how to apply them. Clearly if you assess an anti tank rocket as HT4 and something goes wrong then you only have yourself to blame for trying to blag it into the wrong category.

 

The only time that hazard types are tested by a competent authority is when a product is ready to put onto the market. There are then a number of tests that are done (series 6 tests) to ascertain the classification for transport. This is not always the same as the hazard type of the device as transport involves packaging (which is also tested for strength etc).

 

Hope this helps

[Sparky]

Hi Gareth, do you know what the difference is between 0305 flash powder and 0094 flash powder?

One seems to be 1.1 and the other 1.3?

source is here

Cheers

Martyn

 

I think the 1.3 flash is theatrical flash which is a less vigorous composition, more light etc..

[martyn]

Thanks chaps.

[Rip Rap]

 

Hope this helps

 

Thanks Digger, that does help a lot with understanding and categorising different hazard types. 

Edited by Rip Rap, 27 March 2014 - 12:46 PM.

[Karl]

A massive thank-you to all involved, this is what we've been after for years!