29 replies to this topic

[Arthur Brown]

The current ages are mentioned in the PDF they may be the most appropriate or there may be better. The question quite correctly does not lead, if you wish to comment start at the current position and develop a reasoned argument from there.

[phildunford]

Just let you all know, this is on the management meeting agenda. I have written a draft response and the others will amend. We will be there in time for the deadline.

I'll post it here when we are done...

[TCblastmaster]

Perhaps in order to ascertain what constitutes adequate training for Cat.4 these idiot legislators ought to consult the people who insure professional pyrotechnicians - after all they will base cover/premiums on perceived risk relating to an operator and its employees based on the standard of training received.

A National firework school sounds an interesting concept.

TC

[teaboy]

A 'National Firework School' isn't really required - we just need a decision on what 'competant' means and how we prove it. There then needs to be open access to ALL to learn, train and prove competancy, not just those that work for an association-registered company.

[phildunford]

There then needs to be open access to ALL to learn, train and prove competancy, not just those that work for an association-registered company.

I think that's where most of us are coming from.

There is a real danger that the government will adopt only the BPA route and we must put on all the pressure we can to avoid the exclusion of individuals and non-BPA firms.

Interestingly (as I understand it) the BPA check the balance sheets of firms who apply and can refuse membership. This may be OK for a 'trade organisation' but I can't see that a 'testing organisation' should apply such checks. - Sorry you have not got £10,000 in your bank account so you can't apply for a driving test - I don't think so!

(BTW - I am in no way 'bashing' the BPA here. They have done much good work and it's entirily up to commercial firms which trade associations they join - it just should not be the only way - or if it is, it should be open to all)

Are there any BPA 1 & 2 firers on here that have an opinion on the matter?

[teaboy]

Are there any BPA 1 & 2 firers on here that have an opinion on the matter?

I was BPA Level-1 qualified, but it expired in March 09. I did the course with Fantastic Fireworks when it was a 1-day, £120 course. It's now 2-day £395 course!!

I did the course as it was (is?) the only form of indusrty-recognised professional training and I wanted a career in the industry. If you've NEVER worked with fireworks then it will be very informative. Most people wanting to spend money to learn about fireworks are more than likely to have a decent 'basic' knowledge, but the course was (is?) aimed at the lowest common denominator.

Since working for a non-BPA company for 18 months, and doing the recent Illuminate Consult course I've learned a hell of a lot more, and have only needed my BPA card once (as photo ID for a non-firework related matter!)

It needs to be remembered that the Level 1 and 2 'qualifications' are for FIRERS, not for display companies. You don't 'need' the card to work in the industry, and you may not gain knowledge or experience from the course.

HOWEVER - doing the training currently available shows a will to learn and do things properly.

We're in a really difficult position at the moment, as there isn't an 'industry-standard', let alone Nationally recognised (NVQ, etc). On that basis I would recommend doing the BPA courses, as it can only help you.

[crystal palace fireworks]

As a society we need to be more positive in our attitude & stance.

If we pushed for a firework school that anyone can join (subject to police checks etc), then the proper national qualifications will follow at a "sooner rather than later" date to clarify "CAT4 and specialist knowledge".

This government is hell bent on over-the-top legislation when concerning health & safety,.....so why don`t we take advantage of this consultation and sell them the benefits of a school for fireworks? (even if nothing happens immediately),...the benefits in the long term would far out weight anything the BPA has to offer on so many fronts.

I call it planting seeds!

[teaboy]

As a society we need to be more positive in our attitude & stance.

If we pushed for a firework school that anyone can join (subject to police checks etc), then the proper national qualifications will follow at a "sooner rather than later" date to clarify "CAT4 and specialist knowledge".

This government is hell bent on over-the-top legislation when concerning health & safety,.....so why don`t we take advantage of this consultation and sell them the benefits of a school for fireworks? (even if nothing happens immediately),...the benefits in the long term would far out weight anything the BPA has to offer on so many fronts.

I call it planting seeds!

So long as the government go with the Societies idea, and not with the BPA...

IF they decide that the BPA is the way forward we, as individuals, are still left as outsiders (unless UKPS can become a BPA-registered company).

[crystal palace fireworks]

So long as the government go with the Societies idea, and not with the BPA...

IF they decide that the BPA is the way forward we, as individuals, are still left as outsiders (unless UKPS can become a BPA-registered company).

It doesn`t really matter if the government go down the BPA route at the end of this particular consultation,.....In my opinion this should never deter us from our goal to have a national government backed or run firework school anyway.

Once a firework school is established, then it will become the adopted professional learning centre for pyrotechnics by progression.

Even though we are a small membership society, we should attempt to persuade other professional interest groups (take a look at PDF file) and sell them the idea (subject to a vote by the UKPS members),....if they adopt it, then they will sell it to government anyway.

[phildunford]

After discussions at management meetings the society has compiled the following reply to the ten questions asked and sent it in for Government consideration.

We hope it meets with your approval...

Question 1: Are the definitions of fireworks, set out in schedule 3, which are subject to prohibitions suitable and adequate?

We believe the definitions are both suitable and adequate but observe that any reduction of the variety of effects available to the public can only serve to limit sales and cause damage to the industry.

Question 2: Should the UK retain its existing age limits on the purchase of category 1 fireworks?

12 years old seems a suitable age for this category given that they are not capable of causing any great damage.

Question3: Should we retain the prohibition on breaking up selection packs?

We understand the purpose of this provision is partly to reduce the anti-social use of fireworks. This does not seem logical, as any firework could be used in an anti-social way, irrespective of whether it was taken from a split selection box or purchased individually. It would be better to ensure that people who break the law and cause a nuisance are punished, rather than reducing the choice of the law abiding majority.

Question 4: What are your views on the provisions defining who is a person with specialist knowledge?

This is an area we are particularly concerned about.

There are a large number of experienced firers, who are not associated with BPA registered companies. We do not see that it is necessary to be part of the BPA to be considered a person with specialist knowledge. Over 40 of our members have passed the Category 4 fireworks course run by the independent company ‘Illuminate Consult’. We would suggest that anyone who has passed this course should be considered a ‘person with specialist knowledge’ even though they are not attached to a particular company.

We believe there should be either a national scheme operated by a public body, or any number of recognized schemes offered by providers such as Illuminate Consult - that are deemed to meet show competency / awareness / a minimum level of specialist knowledge to acquire and use pyrotechnic articles.

We believe it is necessary to have a flexible approach which relies upon persons being able to demonstrate to suppliers their experience, training and possession of valid insurance


Question 5: Should there be three separate tests for a person with specialist knowledge?

It seems sensible that there should be separate tests for specialist pyrotechnics such as stage and automotive pyrotechnics.

Question 6: Should the requirement for the marking of a minimum safety distance be maintained for category 4 fireworks and T2 pyrotechnics?

In the case of professional fireworks it would seem that professional judgment would be sufficient. Any additional processes that might increase the cost of the material should be avoided if possible.

Question 7: Is there further provision necessary in relation to enforcement and market surveillance?

We consider the current system to be quite sufficient.

Question 8: Are there other authorities that need to fall within the Directive, the provisions of which exclude the armed forces, police forces or fire departments?

We do not feel qualified to comment on this question.

Question 9: Is the way the free movement provisions works clear; is other provision necessary and in what way could it be justified?

We do not feel qualified to comment on this question.

Question 10: Can you provide any evidence to help inform the Impact Assessment?

It is clear that the burden of regulation over recent years has adversely affected the firework industry in the UK. The reduction in the number of companies manufacturing is a clear indication of this. Your document states that ‘the UK has only one Firework Manufacture’. Although we believe this is not strictly true (Kimbolton, Dean, Spectrum) Kimbolton is certainly the only major manufacturer of consumer & CAT 4 fireworks. Further regulation will only make this situation worse.
The benefits of the free market are of little consolation given the enormous expense of CE marking in this country for even a modest firework.

[starseeker]

Excellent Phil,
it will be interesting to see if we get a reply,

[crystal palace fireworks]

This is a well thought-out reply that covers our concerns, thank you phil, and to all the other ukps staff that compiled the response!

[wayne]

Hi Phil,

The response looks very well constructed with decent arguments put forward. I will be very interested in any response you receive.

Cheers,

Wayne.

[phildunford]

Thanks for your positive responses guys - always tricky to put something together that everyone can agree with!

I think it unlikely that we (or any of the other respondees) will get an individual reply, but if we do, I will certainly publish it here.