exat808

Just a quick update.

I hope to have a draft of the report on the site in the next day or so.

My day jobs have to take priority and I haven't been back at base very much lately. My diary is a bit quieter for the next week so stay tuned. 

Site visit approximately 1500 hrs on 6th February.

Will post some thoughts ( with permission of Icarus) at the earliest opportunity afterwards.

An update for those following the thread.

I was unable to meet Icarus as he didnt read my post or PM until after I had returned to base.

We are in contact and I hope to offer a site visit on 6th February when I will be passing through the area.

Whilst Icarus is on his travels and in the absence of anything else new on the forums I thought that I would post a few thoughts on the ER2014 compliance issues surrounding the "safe legal location" scenario that has been proposed.

 

Much of ER2014 focuses on the concept of a "site" and what can and cannot be undertaken on the "site". The proposed field fits the definition of "site" namely the whole area under the control of the same person. Indeed the "site" in question will no doubt be much larger. "Site" appears in the elements of ER2014 that deal with licensing and matters that would affect a licence such as separation distances. "Site" however does not feature in our particular scenario which concerns the lawful unlicensed manufacture of explosive under the strict criteria at ER2014 Regulation 6(2)(a). The basic concept generally for Regulation 6 deals not with "site" but with "person" and states that no "person" shall manufacture explosives unless that "person" has a licence and then lists the exceptions to that statement of which 6(2)(a) is the one we are considering.

The point that I am putting forward is that on a "site" any number of "persons" can be lawfully benefiting from the 6(2)(a) exemption at any one time. From a compliance perspective the next hurdle to be overcome is that of lawful acquisition of the manufactured substance. My view is that each "person" who manufactures under 6(2)(a) should be the holder of an Acquire Only certificate authorising the acquisition of pyrotechnic substances using the UNMAN2 code that has been described elsewhere on the forums. I would initially anticipate that all manufactured substances will be tested and demonstrated on the "site" as per the criteria of 6(2)(a).

The nuts and bolts detail of safe siting of the sheds and other facilities will be discussed later after site visits.    

We have been discussing ELO continuation training today. Perhaps this might be an appropriate occasion for a UKPS member to come and present your side of things? It wont guarantee exposure to every ELO but it may help.

I will update Wayne by emails with dates etc. Venue is not far from where he lives!!!  

Wayne. If you wish to contact me outside of the forum once you have a list of ELOs we could maybe have yet another attempt at putting some guidance on the right direction. I will be meeting a few of the ELOs next week when they attend a training session that we are running for them.

Below is the body of text from a bulletin that I have sent for inclusion on the ELO intranet site.

Hopefully we can complete the loop now in terms of what to ask for on a certificate application and how the ELO should structure the certificate when it has been granted.

There is still more work to be done on the matter of demonstrating competence.

 

  Explosives Regulations 2014

 

Experimental manufacture of pyrotechnic substances – certification issues

 

This bulletin is for the information of all Explosive Liaison Officers and licensing administrators.

 

Points to note:

 

During the recent Explosive Legislative Review recognition was given to those persons who experiment with the manufacture of pyrotechnic substances as a recreational activity. The HSE worked alongside the lead body for this activity, the UK Pyrotechnic Society (UKPS) to develop the specific exemption from a manufacturing licence found at ER2014 Regulation 6(2)(a).

 

It is improbable that any pyrotechnic substance manufactured in accordance with the exemption will ever be submitted for classification and accordingly a suitable form of words is needed when identifying explosives that may lawfully be acquired on a certificate. Additionally the person conducting the experiments may wish to develop a variety of substances within the life of the certificate.

 

In order to provide a wholly compliant solution to certification issues ELO’s and administrators should use the “UN MAN2” option on NFLMS when selecting from the list of explosives to be authorised. This should generate a descriptor  “Any pyrotechnic substance subject to these regulations that is within the meaning of explosive contained within Regulation 2”

 

It is also recommended that on Acquire Only certificates the permitted use box contains text similar to  “Testing meaning the initiation of an explosive solely for the purpose of evaluating the explosive performance of that article or substance where that evaluation has been undertaken by following a systematic methodology.”

 

Note that some applicants in addition to requesting the UN MAN2 option may legitimately request other commercial pyrotechnic substances such as Flash Powder. Such application should be considered on a case by case basis.

 

UKPS has an excellent guide for those involved in experimental activity. This can be found at:

http://www.pyrosocie...gulations-2014/

 

Information in this bulletin has been made available to UKPS via its internet forum.       

That's a topic title to excite the nation.

 

After a long absence I have returned to UKPS. 

(I haven't really been away as Wayne and others will confirm)

 

I took  the plunge to leave the world of explosives enforcement and to concentrate on my own explosives engineering, training and consultancy activities which have now turned into a full time job across 2 separate businesses. 

 

The aim of this topic is simple - I will answer any explosive legislation based query from forum members but I would prefer the queries to be emailed to me rather than posted on the forum. I will prepare a reply and post that on the forums in due course.

 

My email address - danny@skewenergetics.co.uk

 

I probably wont be checking the forums very often so please use the email option. 

 

Unfortunately, it is quite normal to find trainers and assessor s with far less qualification or experience than the people they are 'training'

You are correct. It has always been a dilemma - who trains the trainers?
There is no industry standard specifically for fireworks/pyro/explosives training and as has been discussed on forums previously; anyone can set themselves up as a training provider. In many ways it is for the person who has been trained to determine if the training was appropriate/relevant/suitable/good value etc etc - but isnt that a back to front way of assessing the competency of a training provider?
I would certainly never advocate Government imposed standards but perhaps the industry should develop some training standards? Without any form of standards or benchmarks to work to then there will always be room for the unscrupulous or incompetent trainer to flourish.

I have just copied this from the BPA website - a perfect example of exploitation of the training requirement of the 2010 Regulations -

On joining the BPA Display Companies must agree to recognize, endorse and promote the BPA Firework Firers training scheme as the only UK qualification meeting the requirement of the Pyrotechnic Articles (Safety) Regulations 2010. To provide training for their operators via the BPA Fireworks Firers training scheme and to maintain this qualification throughout their membership

I cant share a firework "stash" photo so I thought I would share my HT3 and 4 pyro "stash"

I have various well placed contacts within the commercial explosives sector. Would anyone be interested in factory visits to any of the remaining defence contractors who make pyro?
I cant promise anything but I am prepared to ask the questions and make the arrangements. (These visits can only be during the recognised working week - namely Mon-Fri 0800-1700).

Exat's store

Ever the dreamer Karl!!....

We have had similar problems in the Institute of Explosives Engineers for many years. Trying to find a venue for our 2 day AGM/Conference that suits the entire membership has proved impossible. As a way of appeasing as many members as possible we now have a 3 year rotation of North, Midlands, and South. So for example in 2010 we were at Blackpool, 2011 Hinckley (near Leicester), and this year Hayling Island (Portsmouth). Next year we are back in the North again.
You will never please all of the membership all of the time but the rota concept does give many folk a chance of attending AGM,s on a regular basis even if it is not annually.

Another thought might be - why not hold your AGM as a stand alone event at one time of the year and have a separate event for practical activities at another thus giving members 2 opportunities to meet at differing locations.

It could have just been ingredients, AP OR AN can be considered explosives in their own right

It would be useful to know more more about the circumstances but i suspect that Reporters ar restricted in what they can say.
One of the reasons you sometimes see silly mixtures on Mcguyver etc is that regs forbid publishing viable recipies.

There is anti Terror legislation designed to prohibit the gathering or making of information that may be of use to a terrorist. Interestingly the legislation can also be used in circumstances where there is no evidence of actual terrorist activity. This is an extract from the English/Welsh Crown Prosecutors guide -

This legislation also deals with:
collection or making a record of information of a kind likely to be useful to a person committing or preparing an act of terrorism, or possession of a document or record containing information of that kind ("record" includes a photographic or electronic record). (This provision is used to prosecute individuals in possession of "bomb-making" or "anarchist" manuals, even if there is no evidence of actual or intended terrorist activity.)