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ER 2014 - Good practice guidance feedback and discussion


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#76 martyn

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Posted 01 October 2014 - 12:35 PM

I have a direct question I'm hoping Wayne can give me his opinion on. Other people may be in similar circumstances so I'll post it here.

 

I have an acquire &keep for bp, and an acquire only for up to 100g of any pyro comp.

 

Can I mill sub 100g batches of bp and keep them (stored correctly in my approved box  in 550g max containers blah blah). I would be acquiring by manufacture which is covered by both the acquire and the a&k, and then keeping bp under the acquire and keep.

 

Technically I suppose the bp would not be experimental, but I feel it is necessary for testing of other experimental comps and devices and  therefore part of the experiment.

 

Would you agree?

 

My a&k cites the un no's for bp (0027 and 0028), is home made bp automatically given this classification or does it have to be classified somewhere by someone at great expense.

 

Cheers

Martyn



#77 wayne

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Posted 06 October 2014 - 09:00 PM

Sorry for the slow reply!

 

As long as you can justify the storage is for "experimentation", then yes, but keep the stored amount to an absolute minimum.  Remember, you're only allowed 100g NEQ in each experimental device, so it would be hard to justify kg's of stored BP for "experimentation".  What you can't do is use the reg 6(2)(a) exemption as a means of manufacturing BP (albeit in 100g batches) for other uses without manufacturing licence...it all has to be justified as part of an experiment.



#78 martyn

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Posted 07 October 2014 - 10:44 AM

Cheers Wayne, that seems sensible.






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