22 replies to this topic

[whoof]

Do you know what the argument is for 3rd party training ?

[Mixologist]

If you are with and have been trained by a BPA registered company then you will be fine as i understand it.

Who says that the BPA and Illuminate are `approved` though? Does the insurer decide this?

Confusing.

[phildunford]

The whole thing is just a loose agreement really as to what makes a 'competent person'.

I' d love to see a straightforward licence, like a driving licence, but I guess this is too much time & trouble for HMG...

[dogsbody]

Does anyone have a link to this legislation?

[Malcolm Smith]

I' d love to see a straightforward licence, like a driving licence, but I guess this is too much time & trouble for HMG.

Spot on Phil.

The BIS told me that they did not want licencing due to the costs, especially with cuts in the public sector. They are struggling now with their existing work load.

It is a supplier who will be fined if it is found to be supplying CAT 4 fireworks to a person who does not have specialised knowledge, so there will obviously be some tightening up in that direction to cover their behinds.

Here are some links to guidance notes and the legislation.

http://www.legislati...20101554_en.pdf

2. Purpose of the instrument

2.1 The Regulations set out rules concerning the conditions that manufacturers or
importers of pyrotechnic articles need to meet in order to be able to market articles
within the European Union, together with rules concerning the duty of distributors, of
conformity assessment bodies, labelling requirements for articles, enforcement
provisions and various prohibitions on supply of such articles.
------------------------------------------------------------------------------------------------------------------

8.4 A key part of the regime of the Directive is the introduction of the prohibition
on supply of category 4 fireworks, T2 theatrical pyrotechnic articles and P2 other
pyrotechnic articles to persons other than persons with specialist knowledge. The
draft regulations include the prohibition and set out what persons supplying those
articles will need to assure themselves of in order to continue supplying those articles.
Whilst most respondents agreed with the essential elements of the requirements -
training, experience and insurance – there were a number of views expressed on the
detail. The conclusion has been to retain the essentials and refine the precise criteria
in subsequent discussion with the key interested groups.

The new law section:-

http://www.legislati...ulation/42/made

Persons with specialist knowledge for category 4 fireworks, category T2 theatrical pyrotechnic articles or category P2 other pyrotechnic articles 42.—(1) A person with specialist knowledge for category 4 fireworks is any individual who can demonstrate having—

(a) undertaken training recognised in the fireworks business, in relation to the type of category 4 fireworks to be supplied,

(b) used category 4 fireworks; and

© valid liability insurance covering use of category 4 fireworks


(4) The training referred to in paragraphs (1)(a), (2)(a) and (3)(a) must include training in—

(a) the nature and correct use of the articles to be supplied; and

(b) the risks associated with the transport, storage and use of such articles, and includes such training recognised in the relevant business, profession or industry of any Member State.

From the BIS:-

http://www.bis.gov.u...sponse-regs.pdf

"The concept of training recognised in the business, industry or profession does not mean that BIS will be recognising particular training.

It is for the supplier to make a judgement as to whether the training in question is sufficient and provided by a person or body with a sufficient reputation in that sector."

Edited by Malcolm Smith, 09 March 2011 - 03:48 PM.

[Mixologist]

SO they are not actually recognising any form of training, whoever gives it. It would be looked at strictly case by case as i read it.

Therefore, IC course is pretty much pointless from what they were advertising the other day. Unless highlight were to say unless you have BPA or IC we wont supply you.

[phildunford]

Therefore, IC course is pretty much pointless from what they were advertising the other day. Unless highlight were to say unless you have BPA or IC we wont supply you.

Don't think it makes IC pointless, because as Malcolm quotes:

It is for the supplier to make a judgement as to whether the training in question is sufficient and provided by a person or body with a sufficient reputation in that sector.

And BPA & IC training are recognised by all the suppliers I know.

My beef with the BPA training is and has been that it's tied to a particlular firm & BPA choose their members on their own criteria, including turnover, which excludes smaller firms, ones they don't like and all freelance firers unless attached to a BPA company...