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EU pyrotechnics directive call for comment


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#1 pyrotrev

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Posted 06 August 2009 - 01:07 PM

The long dreaded draft of the proposed EU pyrotechnics directive had been published for comment - this could have far reaching impact on our hobby/business, so read and comment!!! no doubt the UKPS will make a formal response, but any of you who have display & sales businesses should also bend the BIS ear. You can find it here: http://www.berr.gov..../page52459.html
Trying to do something very beautiful but very dangerous very safely....

#2 Arthur Brown

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Posted 06 August 2009 - 05:24 PM

Well researched comment would be great. Perhaps the Society could make an official comment.

Please comment individually below, please do not comment "on behalf of the society" unless you are specifically authorised.
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Keep mannequins and watermelons away from fireworks..they always get hurt..

#3 Guest_PyroPDC_*

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Posted 06 August 2009 - 05:30 PM

thats all we need more regulation and rules,

i was reading on section about cat4 fireworks that they want to define who is classed as a professional.

"We believe it is necessary to have a flexible approach which relies on such persons being able to demonstrate to suppliers their experience, training and having valid insurance. We have also sought not to impose a significant increase in the regulatory burden. Part 3 of the Regulations will enter into force on 4 July 2013."

so on one note they say they don't want to impose a increase in regulation burden but they also note in another section that asks the question

"Should there be three separate tests for a person with specialist knowledge?"

more tests, that's all we need.

Edited by PyroPDC, 06 August 2009 - 06:09 PM.


#4 Arthur Brown

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Posted 06 August 2009 - 07:12 PM

The way I read that is that the three tests are one of theatrical, one for cat4 and one for other devices (think Hilti guns and car air bags) Certainly competence with one of these doesn't prove competence with the others.

The "test" for T2, P2, and cat4 is proposed to be

"A person with specialist knowledge for category 4 fireworks is any individual who—
(a) has undertaken training, in relation to category 4 fireworks, recognised in the fireworks business;
(B) can show experience of having used category 4 fireworks; and
© can show evidence of valid liability insurance covering use of category 4 fireworks."

Substitute category T2 theatrical pyrotechnic articles
or category P2 other pyrotechnic articles as appropriate -three rather separate disciplines I think.
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Keep mannequins and watermelons away from fireworks..they always get hurt..

#5 phildunford

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Posted 06 August 2009 - 08:49 PM

I have no objection to tests as such, but don't think much of the way they are done now.

If there must be tests, they should hold legal weight and be available to individuals, who could then show a 'licence' and log of experience to prospective employers.

I'm worried that the BPA tests will become 'law' and it does not seem right to me that such a body could end up saying who can fire and who can't...

I can think of several major display companies who would not want to become BPA members in order to be 'certified'.

I certainly agree that we should make our voice heard on any new laws. If Rich does not pick this up, I'll mention it at the next management meeting.




Teaching moft plainly, and withall moft exactly, the composing of all manner of fire-works for tryumph and recreation (John Bate 1635)
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#6 Mixologist

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Posted 06 August 2009 - 08:56 PM

I have no objection to tests as such, but don't think much of the way they are done now.

If there must be tests, they should hold legal weight and be available to individuals, who could then show a 'licence' and log of experience to prospective employers.

I'm worried that the BPA tests will become 'law' and it does not seem right to me that such a body could end up saying who can fire and who can't...

I can think of several major display companies who would not want to become BPA members in order to be 'certified'.

I certainly agree that we should make our voice heard on any new laws. If Rich does not pick this up, I'll mention it at the next management meeting.


What do you disagree with the BPA?

#7 Arthur Brown

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Posted 06 August 2009 - 09:54 PM

The current BPA structure and test regime is exclusively for employed or engaged firers. Also you must take their training and exams through a member company. The BPA approval is for Firer level 1, and Firer level 2. In NEITHER case would you be a fully competent person to manage the ownership and use of cat4 fireworks outside of your employing (or engaging) company.

In a personal conversation with Roy Musk (one of the two insurers!) he said that he does NOT accept BPA 1 and 2 as adequate training to prove competence as a company principal.

BPA 1 & 2 set standards for firers, NOT competent managers/principals/proprietors
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Keep mannequins and watermelons away from fireworks..they always get hurt..

#8 crystal palace fireworks

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Posted 07 August 2009 - 08:07 AM

I agree with Phil & Arthurs comments entirely.

My personal view is;- I think we need a proper and professional independant government led (and financed) courses/examinations in all aspects of pyrotechnical training (preferably under one roof), and which is open to individuals who are not confined to be affiliated to any other association,... along the lines of perhaps a full and part-time college/university degree course (with different moduals), or a city & guilds qualifications, or BTEC, or NVQ, alongside vocational training in the following;- display set up, insurance, low voltage wiring & safe practice for remote firing, fusing, non-remote firing, practical MSER, ADR, transportation papers for different countries, manufacturing processes of fireworks and sundries, manufacture/design of buildings/premises/land related to firework making & testing, different levels of chemistry courses related to fireworks, making of different fireworks, rigging, props & other devices, safe practical processes with chemistry, patent issues, trade marks, PPE, british standard testing, H&S, small firework manufacture & testing, security vetting, R&D etc.


I would like to see the UKPS press forward the idea of a national firework school to the BIS, or perhaps engage and use MOD premises (on a part-time basis) to allow a better spread/access to courses around the country for us civilians.

If we succeed regarding the above,...then we could have the option of using these premises at weekends for our society use!

Does anyone agree or disagree with this basic proposal?,.......should we not vote on this?

Edited by crystal palace fireworks, 07 August 2009 - 03:49 PM.


#9 phildunford

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Posted 07 August 2009 - 08:51 AM

I suspect one of the reasons the government have gone down the BPA route is that they now outsource everything and see this as an easy (no work) option.

I have no objection to the BPA as such (although I know there are some who do) but feel that such training should be open to all. You don't have to work for a computer company (for instance) to take an MCSE, once you have it, you can then offer your (certified) skills to whoever you want to.

I'm afraid that UKPS do not yet have the clout to make anything happen, but hopefully if we put together a sensible document with our opinion, it may be taken into account.
Teaching moft plainly, and withall moft exactly, the composing of all manner of fire-works for tryumph and recreation (John Bate 1635)
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#10 teaboy

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Posted 07 August 2009 - 11:58 AM

My personal view is;- I think we need a proper and professional independant government led (and financed) courses/examinations in all aspects of pyrotechnical training (preferably under one roof), and which is open to individuals who are not confined to be affiliated to any other association,... along the lines of perhaps a full and part-time college/university degree course (with different moduals), or a city & guilds qualifications, or BTEC, or NVQ, alongside vocational training in the following;- display set up, insurance, low voltage wiring & safe practice for remote firing, fusing, non-remote firing, practical MSER, ADR, transportation papers for different countries, manufacturing processes of fireworks and sundries, manufacture/design of buildings/premises/land related to firework making & testing, different levels of chemistry courses related to fireworks, making of different fireworks, rigging, props & other devices, safe practical processes with chemistry, patent issues, PPE, british standard testing, H&S, small firework manufacture & testing, security vetting, R&D etc.


That'd be perfect. Can't see it happening at the moment though.

I have a feeling that the BPA training will become 'industry standard'(no matter how inadequate it may be).

What's REALLY needed is clear, consistant rules and guidelines that EVERYONE can follow, along with a national qualification so competance can be demonstrated on paper. At the moment it's up to the supplier to decide if someone's experience and training meets the (non-existant) 'standard' despite there being no actual way to demonstrate this.

#11 pyrotrev

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Posted 07 August 2009 - 12:20 PM

Whilst I fully accept that the BPA has done a lot of good for the industry, one objection that's often levelled at them controlling things is that they don't really represent the whole of the industry, just some of the bigger players who may have certain commercial interests that may conflict with the responsibilities of regulation. If they were to open their gates to representatives from smaller display compnies and the UKPS things would be a lot better.

Edited by pyrotrev, 07 August 2009 - 12:22 PM.

Trying to do something very beautiful but very dangerous very safely....

#12 crystal palace fireworks

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Posted 07 August 2009 - 03:33 PM

Yeah your so right Phil, unfortunately our political elites stance on outsourcing, and the spreadsheet cost saving culture of this age, has led to the overall demise of good quality training and services in all industries in this country.

As we all know, the problem is that the BPA is predominately an organisation of display companies and importers,....to me this does nothing to help, encourage, support, or even develope real long term talent for future british manufacturing of fireworks, or in terms of R&D or even the hobbyist,..... although I have nothing against the BPA representing there particular side of the firework industry (As you have said in a roundabout way..."I find its a closed shop that needs to open its shutters").

Maybe if we keep knocking on the door and continue to shout loud enough, maybe someone at government level will take notice and hopefully act on some of our views (please note the deadline of 27.10.2009).

As individuals,...is it a sensible stance to also make our views known directly to the BIS?

Edited by crystal palace fireworks, 07 August 2009 - 03:42 PM.


#13 crystal palace fireworks

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Posted 07 August 2009 - 03:55 PM

That'd be perfect. Can't see it happening at the moment though.

I have a feeling that the BPA training will become 'industry standard'(no matter how inadequate it may be).

What's REALLY needed is clear, consistant rules and guidelines that EVERYONE can follow, along with a national qualification so competance can be demonstrated on paper. At the moment it's up to the supplier to decide if someone's experience and training meets the (non-existant) 'standard' despite there being no actual way to demonstrate this.


Perhaps we should work with an organisation called "The Plain English Society",.....(I think they still exist), they could help our society draft clear precise rules & guidlines.

Edited by crystal palace fireworks, 07 August 2009 - 03:56 PM.


#14 Arthur Brown

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Posted 07 August 2009 - 06:32 PM

A corporate response BY the society would be best. An individual response from outside the professional industry would carry little weight.

An individual response must be clearly marked as such and NO inference of the Society's approval should be attached.
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Keep mannequins and watermelons away from fireworks..they always get hurt..

#15 David

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Posted 08 August 2009 - 04:15 PM

From the article:

" In particular, we are seeking views on the retention of the existing age limits for the purchase of fireworks "

I'm curious as to what else they would consider. Surely not 21? That said, going back to 16 seems equally as unlikely. So what is the talking point?
OK, interest in fireworks to be resumed in the spring. It usually is. ;)




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