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transporting fused items regulations


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#1 Guest_PyroPDC_*

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Posted 30 September 2011 - 12:08 AM

i was having a discussion with fellow firework display owners and some people high up in HSE ect about a discussion i was having on the ukfr and thought id open the discussion on here as we have some very knowledgeable people on here. no names have been added for there protection


so in past threads we have already clarified that you can fuse items including cat 3 and it would not be classed as manufacturing or modifying and you can transport the said article.

but with resent discussions on the ukfr iv had a lot of people that say fusing an firework with an igniter and transporting it is classed as modifying the firework (in transport terms) and therefore would be a un cadded device.

the argument against it is this (a good friend tried to simplify it for me)

transport etc... is all about hazard
not risk
e.g. 6" shell (is 1.3G)... if you add an igniter, it's still 1.3G
because when it explodes
the outcome is identical

1.3 shell + 1.4 igniter = 1.3

also if an firework (cat 4) was made to add an igniter eg Single shot items. by adding the igniter then transporting it you haven't changed the firework and will still perform the way it was designed, (the original debate of why cat 3 fusing should be allowed.)

so since transporting is not about risk but about hazard (yes by adding an igniter you increase the risk BUT the the hazard stays the same (I.E 1.3g)

though visco may be less of a risk than an igniter its still a way of ignition and the mser allows this at the place the storage licence has been issued.

from talks iv been told the gray area is also time fusing because when a cad is given to 1 firework by adding a time fuse to a second firework (eg shell chaining) then you have made a battery and there for change the way the device acts and there loses it cad.


the argument for it is

a Cat4 item like a Single shot unfused with a hole is classified in its packing as 1.3 for example. If, after purchase a fuse is added and the item is then transported then the item has been modified and is no longer the same item that was classified - it may still be 1.3 on subsequent classification but that is for the enforcing authorities to establish.

so please let me know your thoughts but remember this discussions is about transporting (as from what iv been told the mser is open to interpretation but transporting is clear as black and white. but my argument is why would the mser allow fusing (including igniters) if they cant be transported.

Edited by PyroPDC, 30 September 2011 - 12:10 AM.


#2 Mortartube

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Posted 30 September 2011 - 07:43 AM

As far as I understand it, you are still allowed to fuse on site with no licensing etc involved, so why not do that and just avoid the whole grey aea regarding modifying items and transport?

I think the truth is, is that like many regulations, they would be down to someones interpretation on the day if you were stopped whilst transporting fused items most regulations are written in a way they they do not CLEARLY define exactly what can or can't be done and that is why people get hauled through the courts.

If possible, fuse on site is my advice.
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#3 Guest_PyroPDC_*

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Posted 30 September 2011 - 07:58 AM

Idealy that would be the option but this is not always possible, eg Some shows can have over 3000 igniters and even with ten trained workers 6am till 6pm no way would that show be setup in time if all the fusing was done on site

#4 pyrotrev

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Posted 30 September 2011 - 12:10 PM

Idealy that would be the option but this is not always possible, eg Some shows can have over 3000 igniters and even with ten trained workers 6am till 6pm no way would that show be setup in time if all the fusing was done on site

And that's if it's a dry day!

Seriously though, anything that ups the effective hazard category would mean that you'd need to be treating what you're using in a different way. I can't see that normal delay fusing would do that, however shells matched up to fire as one hit very possibly could. A more serious risk is accidental ignition due to mechanical force when igniters are fitted, to educe this I would advise:
1) NEVER slide back the protective shroud - just stick the whole thing down the end of the match.
2) Always make sure there's additional protection - i,e, stick the ingniter in the match inside the top of the tube if it's a candle or cake, or if it's on a free length of match add an outer protective sleeve - a length of 12mm pneumatic tube works well. Single shot deveices with the plastic widget to place the igniter in or e-link connectors do this for you.
Trying to do something very beautiful but very dangerous very safely....

#5 exat808

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Posted 30 September 2011 - 04:13 PM

A direct lift from the HSE guide to classification -

If a change is made to the explosive do I have to re-apply for classification?

23. All significant changes affecting the classification of an explosive should be notified to the HSE and may require the issue of a new competent authority document or other change to the entry in LOCEF. Where any doubt exists with regard to what is significant HSE should be consulted. Examples of modifications which may be regarded as significant include:-


a) A change in the composition of an explosive substance.


b. A change to the quantity or type of explosive filling in an article.


c) A change to the design or specification of the explosive.


d) Any change to the packagings of an article or packaged substance.


Edited by exat808, 30 September 2011 - 04:14 PM.


#6 Guest_PyroPDC_*

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Posted 30 September 2011 - 04:30 PM

but by your own account you can fuse a device and that does not count as changing the specifications or modifying ?

it does not change the way it preforms or change the spec of explosive

are you saying you can not add a piece of visco at your store and then transport it

Edited by PyroPDC, 30 September 2011 - 04:33 PM.


#7 exat808

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Posted 30 September 2011 - 04:56 PM

but by your own account you can fuse a device and that does not count as changing the specifications or modifying ?

it does not change the way it preforms or change the spec of explosive

are you saying you can not add a piece of visco at your store and then transport it


I am highlighting what may be a lack of joined up thinking across the legislation.

Following a logical scenario -

You go to a supplier and purchase an unfused cat4 article.
To transport it to a place of storage it must be in the packaging that the manufacturer used in the classification process and for which a CAD is issued. This is accordance with ADR and the GB domestic transport regs (CDG)
At the storage location MSER applies and you are permitted to fuse your article
Then... you want to take it to a place of use and ADR/CDG come back into play
Is your fused article changed by virtue of its design or specification? Does the original specification exclude an igniter or other fuse? - If yes then contact the HSE and discuss classification - If no then close the box and move it.


You are right - MSER permits fusing at a place of storage. ADR/CDG maybe dont permit the fused articles to be moved away from the place of storage!!! oops

Edited by exat808, 30 September 2011 - 04:58 PM.





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